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and Mrs. Roberts owned an apartment building which contained nine
units located at 3934 Gibraltar Avenue, Los Angeles, California
(the Gibraltar property). Petitioner received rental income and
incurred rental expenses with respect to the Gibraltar property,
but no evidence was presented as to the amounts of any such
income or expenses. Petitioner and Mrs. Roberts also owned
property at 7008 Madden Avenue in Los Angeles.3
The Internal Revenue Service (IRS) determined that
petitioner failed to file his 1983 Federal income tax return (the
Federal return). A notice of deficiency was issued to petitioner
on February 10, 1987. In the notice of deficiency, respondent
determined that petitioner received wages of $29,029, that
petitioner was entitled to one personal exemption of $1,000, and
that petitioner was entitled to single filing status.
Bradford E. Henschel, petitioner's counsel herein, prepared
petitioner's 1983 Federal return and California State income tax
return (the California return). Neither petitioner nor Mrs.
Roberts personally mailed or delivered the Federal return to the
Internal Revenue Service Center in Fresno, California, for
filing. Although neither petitioner nor Mrs. Roberts saw Mr.
Henschel mail the Federal return, they believe he mailed the
3 Mrs. Roberts testified that her father lived at the
Madden Avenue property; whereas, petitioner testified that her
father lived at the Gibraltar property. Thus, it is unclear
whether the Madden property was rental property.
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