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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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