Roger L. and Patricia A. Lavallee - Page 2

                                                - 2 -                                                 
                                         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.                                                



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011