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denominations. On January 11, 1991, Ferrentino presented for
exchange $122,600 in water-damaged currency to the Federal
Reserve Bank in Buffalo. Of the amount presented, $75,000 was in
denominations of $100 or larger.
Ferrentino's Guilty Plea to Filing a False Tax Return
On April 13, 1995, Ferrentino pleaded guilty to a one count
information charging him with willfully making and subscribing to
a false and fictitious U.S. income tax return for the year 1988
in violation of section 7206(1). On January 29, 1996, Ferrentino
filed Forms 1040X, Amended U.S. Individual Income Tax Return, for
the taxable years 1988, 1989, and 1990, which reported additional
income in the amounts of $30,975, $28,870, and $32,572,
respectively.
Respondent Issued Notices of Deficiency After the 3-Year Period
of Limitations on Assessment Had Expired
Ferrentino filed timely tax returns for the 1988, 1989, and
1990 taxable years. AJF, on the other hand, filed its tax
returns late. AJF filed its 1988 and 1989 tax returns on May 10,
1991, and its 1990 return on July 17, 1991.
Respondent mailed notices of deficiency on August 13, 1996,
with respect to petitioners' 1988, 1989, and 1990 income tax
returns. The general 3-year period of limitations on assessment
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