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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Jacksonville, Florida, when they filed
their petition for administrative costs. During the years 1985,
1986, and 1987, Mr. Lavallee was employed as a cross-country
truck driver for Paul Arpin Van Lines, Inc. (Paul Arpin), in East
Greenwich, Rhode Island.
Petitioners filed untimely Federal income tax returns for
1985 and 1986 on July 23, 1987, and for 1987 on November 23,
1988. Mr. and Mrs. Lavallee listed their occupations as "truck
driver" and "homemaker" on their returns for these years. On
Schedule C of their returns, petitioners reported the following
amounts of gross receipts and deductions:
Year Gross receipts Deductions
1985 $100,232 $80,883
1986 102,288 87,797
1987 98,582 90,188
On October 13, 1988, respondent's Office Auditor Linda
Barrow was assigned to examine petitioners' 1986 Federal income
tax return. On October 20, 1988, Office Auditor Barrow sent
2(...continued)
filed on Jan. 26, 1995, and, therefore, has been considered under
sec. 7430 as amended by sec. 6239(a) of the Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat.
3342, 3743-3744, effective for all civil tax proceedings
commenced after Nov. 10, 1988. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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