- 10 - “J. Campbell” was a friend of petitioner. Petitioner testified at trial that Mr. Campbell was a “coventurer” in respect of the certificates issued in their names. Respondent did not include in petitioner’s income $737.50 of interest received in 1990 on the ground that that interest was attributed to Mr. Campbell. In 1992, respondent attributed $3,569.85 to Mr. Campbell, or half the interest income reported on the Form 1099 to “J. Campbell or J. Hernandez” for that year. Every check issued in redemption of the tax certificates at issue, and listed in the amounts described above, was deposited in an account at Florida Federal Savings & Loan Association in Mrs. Hernandez’ name to which petitioner had access, including those amounts not contained in respondent’s adjustments to petitioner’s income. On September 19, 1991, petitioner and Mrs. Hernandez filed a joint income tax return for tax year 1990. On September 18, 1992, petitioner and Mrs. Hernandez filed a joint income tax return for tax year 1991. On October 28, 1993, petitioner and Mrs. Hernandez filed a joint income tax return for tax year 1992. On August 26, 1994, petitioner and Mrs. Hernandez signed a Form 872, printed by the Government Printing Office on green paper, consenting to extend the period of limitations for tax year 1990 until December 31, 1995. Respondent’s authorized agent signed the form on August 29, 1994. On March 20, 1995,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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