- 4 - FINDINGS OF FACT5 When his petitions were filed, petitioner Charles A. McGee resided in Alabama. At all pertinent times petitioner was a self-employed attorney authorized to practice law in Alabama. Petitioner received Bachelor of Arts and Juris Doctor degrees from the University of Alabama in 1972 and 1975, respectively. Petitioner’s law school work included a course in Federal income taxation. During 1987, 1988, 1989, and 1990, petitioner was married to Karen McGee. From 1981 through 1990, petitioner filed only two Federal individual income tax returns: A joint 1980 income tax return with Karen McGee, filed on March 18, 1983, and a joint 1986 income tax return with Karen McGee, filed on October 15, 1987. Petitioner’s Tax Returns On November 27, 1990, respondent notified petitioner’s representative of the initiation of an examination of petitioner’s 1981, 1982, 1983, 1984, 1985, 1987, and 1988 tax years. The scope of the audit was later broadened to include the 1989 and 1990 tax years. On February 12, 1991, respondent received documents purporting to be petitioner’s Federal income tax returns for the 1981, 1982, 1983, 1984, 1985, 1987, 1988, and 5 The stipulation of facts and the attached exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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