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12, 1987, petitioner filed a Form 2688, Application for
Additional Extension of Time to File U.S. Individual Income Tax
Return.
On October 15, 1987, petitioner filed his 1986 Form 1040,
U.S. Individual Income Tax Return. On Schedule E, Supplemental
Income and Loss, petitioner reported the following net income
from petitioner’s stock dealings in Hammermill:
Item Amount
Bilzerian & Mack $1,840,003
Bilzerian Investors 10,216,579
Bilzerian Ventures 3,107
Total 12,059,689
On the Schedule C, Profit or Loss from Business, petitioner
reported gross income of $8,063,277 from the sale of securities.4
On the Form 1040, petitioner reported adjusted gross income and
tax liability of $6,099,966 and $3,005,166, respectively.
Petitioner reported an overpayment of tax of $2,053,708.
Petitioner’s 1986 individual tax return was prepared by
Dwight Norris (Mr. Norris). Mr. Norris prepared petitioner’s
individual tax returns for the taxable years 1982 through 1986.
Mr. Norris also prepared partnership tax returns for 1986 for
South Bay Fashion Center and South Bay Fashion One.5 Mr. Norris
graduated from Ohio State University in 1956 and has been working
4Petitioner reported deductions of $14,101,394, resulting in
a net loss of $6,038,117.
5In 1982, Mr. Norris was a business partner with petitioner
in South Bay Fashion One.
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