-3- 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011