Robert E. Iles and Monica M. Iles - Page 3

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               By amendment to answer, respondent asserts in the                      
          alternative that, if petitioner Robert E. Iles is not liable for            
          part or all of the additions to tax for fraud for any of the                
          years in issue, then he is liable for additions to tax under                
          sections 6653(a) (negligence) and 6651(a) (failure to timely file           
          tax returns) for those years.                                               
               On April 14, 1988, after respondent issued the notices of              
          deficiency and a joint petition was filed as to all 3 years,                
          petitioners Robert E. Iles, hereinafter sometimes referred to as            
          Robert, and Monica M. Iles, hereinafter sometimes referred to as            
          Monica, filed joint tax returns for 1981 and 1982.  See Phillips            
          v. Commissioner, 86 T.C. 433 (1986), affd. on this issue and                
          revd. on another issue 851 F.2d 1492, 1496-1498 (D.C. Cir. 1988),           
          discussing the effect of filing joint tax returns under such                
          circumstances.  In the above-noted amendment to answer,                     
          respondent recomputed the deficiencies for 1981 and 1982 by                 
          combining the adjustments to income determined in the separate              
          notices of deficiency and using joint filing rates.  Respondent’s           
          recomputation also reflects respondent’s position regarding                 
          income reported and deductions claimed on petitioners’ late-filed           
          tax returns, makes certain concessions, and increases some income           
          items.  See sec. 6214(a).  The results of respondent’s                      
          recomputation are as follows:                                               







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