- 5 - petitioner and the revenue officer discussed the unfiled 1981 tax return. On September 13, 1985, petitioner sent his untimely original 1981 income tax return dated "9/13/85", which showed no tax due, to the revenue officer. Petitioner in his cover letter indicated that the return was recently prepared. When the revenue officer received petitioner's document, he found one "Schedule C" business was on a marked-up 1982 Form 1120S, U.S. Small Business Corporation Income Tax Return, and another on a marked-up 1980 Form 990, Return of Organization Exempt from Income Tax. Petitioner called and asked the revenue officer if it was "all right". The revenue officer told him that the businesses should be reported on Schedules C. Apparently, it was agreed that the return would be returned to petitioner, together with the proper schedules for preparing a correct return. The revenue officer indicated in his records that petitioner would complete the schedules and file a correct return. Petitioner failed to do so. The revenue officer did not retain a copy of the untimely original 1981 income tax return in respondent's administrative file. Shortly thereafter, respondent's Criminal Investigation Division (C.I.D.) commenced a criminal investigation of petitioner. Respondent finished the examination of petitioner's income tax for the tax year 1981 after the conclusion of the criminalPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011