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On occasion, petitioner inquired of Martin as to the amount
of his income and as to the family’s annual living expenses.
Martin responded with vague and general answers and refused to
provide any specific information to petitioner.
Martin and Petitioner's Joint Income Tax Returns
and Respondent's Audits
For years prior to 1981, and for 1981, 1982, 1983, and 1984,
Martin and petitioner filed joint Federal income tax returns. It
is not clear from the record who prepared the joint Federal
income tax returns filed by Martin and petitioner for years prior
to 1981. For 1981 and 1982, Martin prepared the returns. For
1983 and 1984, an accounting firm prepared the returns with the
assistance of Martin.
After the tax returns for each year were prepared, Martin
presented the returns to petitioner for her signature without
giving petitioner any realistic opportunity to review the
returns, presenting petitioner with the returns only after they
had been prepared and insisting that she sign the returns
immediately. This was Martin's general practice with regard to
all documents signed by petitioner.
The schedule below reflects Martin and petitioner's joint
Federal income tax liabilities for 1970 through 1980 as reported
on their returns:
Year Tax Liability
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Last modified: May 25, 2011