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In the years 1990 and 1991, petitioner was a financial
planner. He received compensation from multiple sources such as
insurance and investment companies. Petitioner also paid
commissions to other individuals for which he was entitled to
business expense deductions. In 1990, petitioner received
compensation from at least six sources. In 1991, he received
compensation from 15 sources. Some of petitioner's compensation
was reported on Forms W-2 and some on Forms 1099. In each year,
petitioner received more than one income statement from at least
one company.2
Petitioners filed for, and were allowed, an extension of
time to file their Federal income tax return for taxable year
1990, extending the due date to October 15, 1991. Their 1991
return was due on April 15, 1992. Both returns were filed on
October 19, 1992.
Sometime prior to October 19, 1992, petitioners received a
letter from the Internal Revenue Service (IRS) requesting
petitioners to bring in their records at a specified time for
purposes of preparing a return. Just prior to the scheduled
meeting, petitioner filled out portions of the returns (Forms
2 In 1990, petitioner received two Forms 1099 from Security
Life of Denver, and both a Form 1099 and a Form W-2 from New
England Mutual Life Insurance Co. The Form 1099 from Gordon
Anthony for 1990 is marked "corrected", indicating a previous
incorrect form had been issued. In 1991, petitioner received
both a Form 1099 and a Form W-2 from New England Mutual Life
Insurance Co. and two Forms W-2 from Provident Mutual Life
Insurance Co.
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