Stanley L. Wade - Page 5

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          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 document                 






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