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Prior to her marriage to Mr. Freidus, petitioner regularly
filed Federal income tax returns. While petitioner was aware of
her duty to file income tax returns and the consequences arising
for failing to file, she did not file Federal income tax returns
for her 1987, 1988, 1989, and 1990 taxable years. Petitioner was
also aware of her right to request extensions to file her tax
returns, but did not request extensions to file her returns. The
last return petitioner filed was for the 1980 taxable year.
Petitioner also knew of her obligation to make estimated tax
payments, but failed to do so for the 1987, 1988, 1989, and 1990
taxable years.
Petitioner believed that a 1990 return, if prepared, would
indicate that she owed taxes. Petitioner also believed that she
would owe taxes for 1987 had a return been prepared.
During the years in issue, petitioner's income consisted of
the following:
Horse Show
Year Income Interest Capital Gains Rents
1987 $246,614 $15,027 $195,631 $154,833
1988 104,166 15,427 903,018 127,943
1989 197,287 1,991 380,114 27,802
1990 133,578 7,489 3,179,663 9,184
Petitioner made the following purchases at Christie's
auctions:
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