Wilburn C. Hall, Jr. - Page 15

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          memory, estimating figures, and looking at old check registers              
          and assorted receipts. At the time of filing his tax returns for            
          the years in issue petitioner did not keep his tax records in an            
          organized manner.                                                           
          On his 1982 tax return, petitioner reported his rental                      
          income on line 24 (other income) of the Form 1040, and did not              
          provide any information as to what the properties were, what the            
          gross rentals were, and what the expenses were. On his Schedule             
          C, he reported only the total amount of the deductions (with a              
          breakdown of the deductions on separated sheets attached to the             
          tax return) but no gross receipts from any business or                      
          profession; six of the items on the expenses breakdown are shown            
          as estimates. On his Schedule D, he reported a net amount for               
          capital gains, without showing any of the other information                 
          required by the form. Similarly, on his Schedule E, he reported             
          merely a lump sum of royalty income; he did not provide any                 
          information as to what the properties were, what the gross                  
          royalties were, and what the expenses were. Similarly, on his               
          Schedule F, he reported merely a lump sum of gross income from              
          farming, without any of the other information required by the               
          form.                                                                       
          On his 1983 tax return, petitioner failed to attach                         
          Schedules D and E, even though he reported on the Form 1040 that            
          he had income from capital gains, rents, and royalties.                     
          On his 1984 tax return, petitioner failed to attach                         




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