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subsequently called Mr. Givens to reschedule the meeting for
February 11, 1993.
On February 9, 1993, petitioner signed an Amended U.S.
Individual Income Tax Return (Form 1040X) for each taxable year
in issue. These amended returns, prepared by Mr. Clark and filed
with respondent, reflect the payments petitioner received from
Mr. Hall in the amounts as stated in petitioner's November 21,
1992, affidavit. The original and amended returns reveal the
following taxable income and total taxes for the years in issue:
Original Returns Amended Returns
Year Taxable Income Taxes Taxable Income Taxes
1989 $40,010 $9,931 $182,387 $55,888
1990 20,582 3,086 97,032 25,342
1991 67,157 16,713 252,840 73,943
The increased tax liability resulting from the inclusion of the
payments from Mr. Hall, as reflected on the amended returns, was
paid by petitioner with the filing of the amended returns.
In the notice of deficiency, respondent determined that
petitioner's correct taxable income and taxes, after adjustments
and corrections, were as follows:
Taxable Total Tax
Year Income Liability
1989 $182,387.00 $54,935.00
1990 96,302.00 25,101.00
1991 256,237.19 76,583.83
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