- 5 - David pleaded guilty to various counts of fraud involving the sale of unregistered securities in connection with his participation in the fraudulent investment scheme. On their 1984 and 1985 returns, David and petitioner reported adjusted gross income of $10,525 and $4,298, respectively, of which approximately $9,801 in 1984 and $1,760 in 1985 represented petitioner's wages from part-time nursing. Petitioner signed the 1984 return on June 16, 1987, and the 1985 return on November 9, 1987. At the time she signed the 1984 and 1985 returns, petitioner questioned David about why the returns contained no income reflecting the money that he had given her in those years. She stated that he gave her such a bizarre explanation that I don't think I could even repeat it, I mean what he told me. * * * It was something along the fact that it had been investment--that he had investments in * * * [Hitech] that had been lost and this was return, or something along those lines. * * * it just didn't make sense to me. Petitioner suspected that David was lying, but she would not press him further on the matter. David had gotten violent when Margaret or others "probed" into his finances. Discussion Reconsideration under Rule 161 serves the limited purpose of correcting manifest errors of fact or law, also allowing for the introduction of newly discovered evidence that could not have been introduced before the filing of an opinion, even if the moving party had exercised due diligence. See Estate ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011