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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.
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