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reimbursement relates back to expenses she incurred for a rental
car prior to March 1993.
Petitioner admits that she utilized the rental car for
personal as well as business uses. Petitioner conceded using the
rental car for shopping trips, transportation to Masonic
conventions, trips to church, and other trips of a personal
nature. The record also indicates petitioner authorized other
individuals to drive the rental car.
According to IRS records, petitioner did not file a request
for extension of time in which to file her 1993 or 1994 Federal
income tax returns. Petitioner claims that one of her tax return
preparers informed her that she had filed the required extension
requests for both 1993 and 1994. Petitioner further alleges that
she never received copies of these extensions from her preparers
and therefore is unable to provide the Court with copies of these
extensions. Petitioner was unable to locate her tax return
preparers prior to trial. On petitioner's 1993 and 1994 Federal
income tax returns, the tax return preparer identified his
business address as a post office box in Philadelphia,
Pennsylvania.
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