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Pursuant to the 1987 and 1988 unsigned amended returns and
voluntary payments, respondent assessed additional taxes in the
amounts of $68,255 on September 17, 1992, for 1987, and $48,887
on September 1, 1992, for 1988.
OPINION
Issue 1. Assessments of Voluntary Payments
Petitioners contend that their voluntary payments submitted
with unsigned amended income tax returns were improperly
assessed. After entry of the judgment of conviction in the
criminal tax case against petitioner, and while it was on appeal,
petitioners made the voluntary payments to respondent.
In the notice of deficiency dated September 4, 1992,
respondent determined that there were deficiencies in income
taxes due from petitioners in the amounts of $67,485 and $49,419
for 1987 and 1988, respectively. In paragraph 3 of their
petition filed on November 27, 1992, petitioners conceded the
deficiencies in income taxes for 1987 and 1988.
On August 10, 1994, petitioners filed an amended petition.
In paragraph 2 they alleged that the deficiencies for 1987 and
1988 were in dispute. In paragraph 3 of the amended petition,
however, they limited this "dispute" to an alleged error by
respondent in assessing the deficiencies. The facts stated in
paragraph 4 of the amended petition and the prayer for relief are
centered around respondent's assessments of the taxes.
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