- 4 -
For 1988 and subsequent years, the record contains little
reliable evidence as to petitioner's tax bases in, and the value
of, petitioner’s stock of each of the S corporations.
As of the end of 1987, petitioner apparently had received
from Car Stereo and/or the other S corporations $148,574 in the
form of a corporate loan. The evidence is unclear as to whether
and, if so, to what extent petitioner ever repaid this purported
loan.
In the late 1980's or early 1990's, the accountant who
maintained petitioner’s books and records and who was to prepare
Federal income tax returns for petitioner personally and for
petitioner’s S corporations closed his accounting practice and
disappeared. Many of the financial records relating to
petitioner’s individual Federal income tax liabilities and
relating to petitioner’s S corporations were never recovered from
the accountant. Also, during these years, petitioner experienced
significant personal and family problems that interfered with
petitioner’s ability to timely file his Federal income tax
returns.
Petitioner untimely filed his individual Federal income tax
returns for 1989 through 1993.
On his 1990 individual Federal income tax return, petitioner
did not reflect the $8,275 that he paid to the State of New York
relating to the outstanding sales tax liability of Car Stereo.
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