- 3 -
Trial and resolution of this case have been complicated by
the failure of petitioners to cooperate with respondent's
representatives during respondent's audit and by petitioners'
failure to comply with important aspects of this Court's pretrial
and trial rules.
For convenience, we combine our findings of fact and
opinion on each issue.
Some of the facts have been stipulated and are so found.
At the time they filed their petition in this case, petitioners
resided in Carmi, Illinois.
During 1980 through 1985, petitioner Daniel R. Leavell
(Daniel) was engaged in the conduct of various businesses
involving oil production, the sale of oil field equipment, and
the maintenance of oil wells. In 1984, petitioner Eva Lovene
Leavell (Eva), under the name of L & L Supply, began a separate
business involving the sale of oil field equipment. In 1986, Eva
operated a separate business involving oil production.
Filing of Petitioners' 1985, 1986, and 1987 Joint Federal
Income Tax Returns, Respondent's Audit, and Trial
On October 17, 1988, petitioners untimely filed their joint
Federal income tax return for 1987. On May 10, 1990, petitioners
untimely filed their joint Federal income tax returns for 1985
and 1986. On September 27, 1990, petitioners filed an amended
joint Federal income tax return for 1987.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011