- 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
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