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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 criminal
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