Jane B. Oliver and Robert P. Oliver - Page 3

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          February of 1991; (7) whether petitioners are entitled to                   
          Schedule C business expense deductions for legal and professional           
          expenses of $10,000 claimed for 1990 and $13,000 for 1991; (8)              
          whether petitioners failed to report interest income of $2,824              
          for 1990; (9) whether petitioners are entitled to Schedule C                
          business expense deductions for self-employment tax of $7,849 for           
          1990 and $10,246 for 1991; (10) whether the assessment of a                 
          deficiency for the taxable year 1990 is barred by the 3-year                
          period of limitations provided in section 6501(a); (11) whether             
          petitioners are liable for the additions to tax pursuant to                 
          section 6651(a)(1) for failure to file timely Federal income tax            
          returns for 1990 and 1991; and (12) whether petitioners are                 
          liable for accuracy-related penalties pursuant to section 6662(a)           
          for 1990 and 1991.                                                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the attached exhibits            
          are incorporated herein by this reference.                                  
               At the time the petition was filed in this case, Jane B.               
          Oliver and Robert P. Oliver resided in Greenville, Mississippi.             
          Petitioners, who are cash basis taxpayers, filed their joint                
          Federal income tax returns for the taxable years 1990 and 1991 on           
          August 19, 1991, and July 20, 1992, respectively.                           








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