Otelio S. Randall - Page 4

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               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.                      




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