- 6 - time of his tax return preparation, inquired of his return preparer about whether an inheritance from his father was taxable. Edgar was not knowledgeable about the legal proceedings brought by the State. He believed that because he had already received the money from his father’s trust, it was his inheritance. The return preparer, a certified public accountant who specialized in taxation and who had prepared Edgar’s returns since 1969, after hearing the facts of which Edgar was aware, advised that it was not taxable. On Edgar’s 1989 Federal income tax return, he reported three items of income as follows: $3,122 interest, $1,419 gross business receipts, and $7,405 as a nontaxable pension. Edgar’s 1989 Federal income tax return was timely filed on October 15, 1990, pursuant to extensions to file granted by respondent. On September 5 and 6, 1996, the Internal Revenue Service and Edgar signed an agreement consenting to extension of the period for assessment of his 1989 tax year to December 31, 1997. On May 20 and 29, 1997, a similar consent was executed to extend the period to December 31, 1998. The notice of deficiency for the 1989 tax year was mailed to Edgar on August 27, 1998. A 1989 return was not filed for Victor, the trust, or Magna Carta. Victor’s estate was not probated, and an estate tax return was not filed for Victor’s estate. Magna Carta paid anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011