Robert E. Iles and Monica M. Iles - Page 35

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          Rolls Royce.  The capital contributions by SSI on behalf of                 
          petitioners are 1982 income to petitioners.                                 
          S.  Tax Returns                                                             
               Petitioners are cash basis taxpayers.                                  
               1.  Petitioners' 1980 Tax Return                                       
               On April 15, 1981, petitioners filed for an extension of               
          time to file their 1980 tax return.  Respondent granted to                  
          petitioners an extension to June 15, 1981.  Additional extensions           
          for petitioners' 1980 tax return were neither sought by                     
          petitioners, nor granted by respondent.  Petitioners filed their            
          joint 1980 tax return on September 18, 1981.                                
               On their 1980 tax return, petitioners reported (1) $79,989             
          gross income and $71,154 net profit from Associates, (2) $19,010            
          gross income and $39,128 net loss from Robert Iles Computer                 
          Services, and (3) a $13,860 net loss from Robert Iles, et al.               
          Petitioners reported their total 1980 tax liability as $5,541               
          ($1,283 income tax, $1,471 self-employment tax, and $2,787 tax              
          from recomputing prior-year investment credit).  Below their                
          signatures, petitioners wrote the following:  "This return was              
          prepared under duress due to summons and it will be amended."               
          However, petitioners never amended their 1980 tax return.                   
               2.  Petitioners' 1981 Tax Return                                       
               On April 15, 1982, petitioners filed for an extension of               
          time to file their 1981 tax return.  Respondent granted to                  





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