- 3 - Respondent filed an answer to the petition denying all substantive allegations of fact and error contained in the petition. In addition, respondent made affirmative allegations of fact in support of respondent's determination that petitioners are liable for additions to tax for fraud. Specifically, respondent alleged that petitioners: (1) Failed to file timely income tax returns for the years 1987 through 1992; (2) failed to cooperate with the revenue agent conducting the audit of their tax liability for 1987 through 1993; (3) failed to maintain and/or provide respondent with complete and accurate records concerning their income and expenses; (4) failed to provide the account numbers or bank names for all accounts that they maintained during tax years 1987 through 1993; (5) fraudulently and with the intent to evade the payment of tax understated gross receipts in the amounts of $84,245.08, $166,894.49, $230,670.52, $248,756.27, $359,718.81, $292,114.15, and $453,071.47 for tax years 1987 through 1993, respectively; (6) fraudulently and with the intent to evade the payment of tax failed to report $3,035 and $1,000 of other income received during tax years 1987 and 1992, respectively; (7) fraudulently and with intent to evade the payment of tax claimed false net operating loss carry forwards in the amounts of $19,455, $29,091, $36,439, $38,680, and $99,818 on their income tax returns for 1988 through 1993, respectively;3 3 The correct tax years with respect to this allegation are 1988 through 1992.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011