- 12 - resources were available to him from his business interests in the Philippines. Ms. Yue and her supervisor accepted Mr. Makalintal’s explanation and finalized the return for Mr. Makalintal’s and petitioner’s signatures. When Mr. Makalintal gave petitioner the 1986 joint income tax return for her signature, petitioner reviewed the return, and petitioner also specifically asked Mr. Makalintal how Mr. Makalintal and she were able to afford such a high standard of living in light of the income reported on the return. Mr. Makalintal informed petitioner that he had access to funds in the Philippines that had been earned in years prior to 1986 and that were not reportable as income for 1986. Because, among other reasons, Mr. Makalintal frequently represented that his business interests in the Philippines were successful and because Mr. Makalintal used an accounting firm to prepare the income tax return, petitioner accepted Mr. Makalintal's explanation of the income reported on the 1986 return, and petitioner signed the return. In connection with her review and signing of the 1987 and 1988 joint Federal income tax returns, petitioner again asked Mr. Makalintal about the income reported thereon in light of the money they were spending. Mr. Makalintal again reassured petitioner that he had available nontaxable financial resources from the Philippines.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011