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Mischel for tax pertaining to the taxable year 1986 "based on
fraudulent information furnished by respondent".
The entry for "tax withheld" in the amount of $303,114.25
apparently relates principally to what petitioner believes was
the fraudulent income amount for the taxable year 1986 that was
furnished by respondent to the Arizona Department of Revenue and
that led to the "Arizona tax based on fraudulent IRS information"
described above.
The entry for "estimated tax payment" in the amount of
$602.50 represents the alleged out-of-pocket cost incurred by
petitioner and Mr. Mischel in traveling to respondent's service
center in Ogden, Utah, in February 1992 in order to review their
tax records for prior years.
The entry for "tax informant fee" in the amount of $47,000
represents 25 percent of $188,000. This "fee" was claimed by
petitioner on the basis that she and Mr. Mischel exposed "the
fraudulent IRS claim" described above.
Respondent did not process the Form 1040A as an income tax
return. Rather, respondent treated it as a frivolous return and
assessed the frivolous return penalty under section 6702 against
petitioner in the amount of $500.
D. Petitioner's Form 1040X
At trial, petitioner tendered to the Court a Form 1040X
(Amended U.S. Individual Income Tax Return) for 1992 (the Form
1040X), which mirrored the Form 1040A, except for the following:
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