-4-
familiar with Internal Revenue Code provisions dealing with real
estate transactions. He prepared petitioners' tax returns for
each of the years in issue. Mrs. Goldberg signed the returns,
but petitioner did not go over the contents of the returns with
her nor did she review the returns line by line.
Petitioners reported the receipt of the following amounts on
their 1988 return:
Rents $58,955
Interest 3,359
Dividends 877
Taxi 19,500
Petitioners' 1990 and 1991 returns were received by the
Laguna Niguel District Office on October 18, 1991, and
October 15, 1992, respectively. Although each return indicated
that an extension of time to file had been obtained, each
reported that no payment had been made with the extension
request.
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