- 5 - and petitioners’ 1982 and 1983 joint Federal income tax returns reflected that petitioners owed no Federal income tax. On audit for 1982 and 1983, respondent determined that petitioners, on their 1982 and 1983 joint Federal income tax returns, fraudulently understated their income from their apartment rental business, and respondent determined for those years the fraud additions to tax and the substantial understatement addition to tax. Respondent's notice of deficiency for petitioners’ tax years 1982 and 1983 was mailed to petitioners on December 15, 1993. Respondent's separate notices of deficiency to petitioners for 1984 were also mailed on December 15, 1993. Petitioner Janet Wade did not file a petition as to the notice of deficiency she received for 1984. During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S. Individual Income Tax Return) that purported to be a copy of petitioners’ 1984 joint Federal income tax return that was allegedly filed by petitioner in 1988 and that reflected a tax due of $386. At the time of trial, respondent's computer records indicated that neither petitioner had filed a Federal income tax return for 1984 and that neither petitioner had paid any income tax for 1984. Respondent did not accept or treat the above Form 1040 as "filed" by petitioners in 1993 because the documentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011