- 4 - Shortly after Mr. Todar notified petitioner of the clinic break-in and asked him to attempt to duplicate the destroyed records, petitioner provided Mr. Todar with all of the informa- tion that he needed to prepare petitioner's 1991 return, except the contractor receipts and certain other records relating to the catering activities of his wife during 1991. Petitioner requested and was granted one extension of time until August 15, 1993, within which to file his 1992 return. Petitioner did not file returns for the taxable years 1991 and 1992 prior to the issuance of the notice of deficiency (notice) on June 30, 1995. On September 28, 1995, and September 29, 1995, respectively, respondent received Forms 1040 (U.S. Individual Income Tax Returns) for taxable years 1991 and 1992 that were signed by petitioner and his wife as the taxpayers and by Mr. Todar as the return preparer.3 At least as late as the summer of 1996, petitioner had available original records relating to certain deductions claimed in his 1991 and 1992 returns with respect to his wife's catering activities. Those original records were misplaced by petitioner and/or his wife sometime during and/or after the summer of 1996. During 1996, petitioner produced copies from originals of American Express and similar monthly statements and receipts that were relevant to his 1991 and 1992 returns. 3 Petitioner's wife is not a petitioner in this case.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011