Beverly D. Goings - Page 6

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          Bordelon's payments to Mr. Goings at the time she prepared the              
          couple's joint returns for taxable years 1985 through 1988.                 
          She first learned of such payments when Mr. Goings inquired as to           
          the procedure for filing amended tax returns sometime in 1989.              
          Petitioner did not review any of the couple's joint returns prior           
          to signing them.                                                            
               In September 1989, the IRS initiated an examination of                 
          Bordelon's 1987 Federal individual income tax return.  That                 
          examination revealed Bordelon's kickback payments to Mr. Goings.            
          The examination also revealed that Bordelon had not issued a Form           
          1099 to Mr. Goings with respect to any of the kickback payments.            
          Bordelon subsequently issued a Form 1099 to Mr. Goings with                 
          respect to the payments made in taxable years 1986, 1987, 1988,             
          and 1989.2                                                                  
               In November 1989, after receiving the Forms 1099 from                  
          Bordelon, Mr. Goings and petitioner filed amended tax returns for           
          taxable years 1986, 1987, and 1988 (the amended returns).  Each             
          amended return listed the kickback payments as income and                   
          contained the corresponding additional tax payment.  Petitioner             
          and Mr. Goings did not amend their 1989 tax return, and it is               
          unclear from the record whether they amended their 1985 or 1990             
          returns.                                                                    


               2It is unclear from the record whether Bordelon issued a               
          Form 1099 to Mr. Goings with respect to the payments made in 1985           
          and 1990.                                                                   




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