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30. Each of the Forms 1040 contain the petitioner
Wayne E. Wells' name and address. On line 7 for wages,
salaries, tips, etc., was written the word "Estimated."
31. The respondent processed the 1040 for 1986 as
a valid, albeit delinquent, federal income tax return,
but the respondent determined that the Forms 1040 for
1987, 1988 and 1989 were not valid returns and did not
process them as valid returns.
32. The respondent used Bureau of Labor
Statistics to partly or wholly determine the income for
petitioner Wayne E. Wells during the four tax years
1986, 1987, 1988 and 1989. The respondent used the
income figures of all urban consumers for a family of
four living in Dallas, Texas, at the intermediate
family level, relying on 1981 as the base year, when
petitioner's Wayne E. Wells income was $22,678.00.
Those computations are reflected in the three-page
Exhibit 13-M.
33. Based solely on those Bureau of Labor
Statistics figures, petitioner Wayne E. Wells had
partial earned gross income for the taxable years 1986,
1987, 1988 and 1989 in the amounts of $27,341.00,
$28,325.00, $61,672.00 and $30,902.00, respectively.
34. From January 1, 1986, to April 8, 1986,
petitioner Wayne E. Wells earned income from Casualty
Reciprocal Exchange reported on a Form W-2 in the
amount of $13,419.36; that amount was included by the
respondent as part of the earned gross income for 1986
of $27,341.00.
35. The respondent also determined that
petitioner Wayne E. Wells' received additional income
during the taxable year 1988 when his profit-sharing
plan with the Dodson Group, of which Casualty
Reciprocal Exchange was a member and the petitioner's
actual employer, was liquidated. It was liquidated
when the IRS seized the money to pay off past
assessments. This amount was $32,185.00 and was
received from the trustee, United Missouri Bank of
Kansas City, Trust Division. The respondent also
determined that petitioner Wayne E. Wells received
additional income in 1988 in the form of interest from
the U.S. Treasury Department, in the amount of $30.00.
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