- 3 -
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation and
exhibits submitted therewith are incorporated herein by this
reference. At the time the petition was filed, petitioners
resided in San Antonio, Texas.
On December 21, 1993, respondent received a Form 1040 for
1992 signed by petitioners and purportedly dated April 9, 1993.
Every line of the form was filled out "Object--5th Amend." or
with zeros. Attached to the form were various appendices
including a "legal brief" and an "administrative claim for refund
and a demand for hearing and abatement, tax year 1992". In
addition, petitioners attached various Forms W-2 and 1099,
statements showing distributions from Dean Witter Trust Co. (Dean
Witter) and Great American Reserve, and a Schedule K-1 showing a
partnership distribution to Beatrice Sochia.
Petitioners filed a Form 1040 for 1993 on or about April 15,
1994. Most of the lines on that form (including line 31,
adjusted gross income) also were completed "Object--5th Amend."
However, petitioners included numbers for a business loss on line
12. Numbers were also shown on some of the lines for Schedules A
and C, and for the Forms 8283, 2106, and 6251 which were attached
to the Form 1040. Other lines had question marks or, in the case
of Form 4797, which was also attached to the Form 1040, "Object--
5th Amend." As part of the package, petitioners included Forms
1099, a "statement of account" by Dean Witter, annual statements
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011