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District Court for the Northern District of Florida, pursuant to
section 7207 for willfully filing false Federal income tax
returns for taxable years 1986, 1987, and 1988.
Before the conclusion of the criminal proceedings against
Briggs and Mr. Morris, Towers Construction filed amended income
tax returns for at least 1986 and 1987 reporting at least some
previously unreported gas rebate income.5 The amended returns
included Schedules K-1, Shareholder’s Share of Income, Credits,
Deductions, Etc., reflecting that Briggs and Mrs. Morris were
allocated equal shares of all the gas rebate income.
Petitioners filed amended individual income tax returns to
reflect the amounts of income reported on the amended Schedules
K-1.6
5 On July 6, 1992, Towers Construction filed untimely
amended tax returns for 1986 and 1987. The record contains no
amended return filed by Towers Construction for 1988. The
notices of deficiency, however, make reference to amended
Schedules K-1, Shareholder’s Share of Income, Credits,
Deductions, Etc., from Towers Construction for 1988, reflecting
corrected shares of gas rebate payments, from which we infer that
Towers Construction filed an amended return for 1988 reporting
previously unreported gas rebate income.
6 On July 6, 1992, petitioners filed amended tax returns for
1986 and 1987. Briggs also filed an untimely 1988 return on July
6, 1992. The record contains no amended return for the Morrises
for 1988. The notices of deficiency, however, appear to be
predicated on petitioners’ having reported on amended returns the
amounts of gas rebate income reflected on the amended Schedules
K-1 from Towers Construction, from which we infer that the
Morrises filed an amended return for 1988 reporting gas rebate
income as reflected on the corrected Schedules K-1.
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