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October 4, 1993. Respondent's transcript of petitioner's
account for 1990 does not reflect that petitioner filed a
return. This is due to the fact that respondent had filed
a substitute return for petitioner under section 6020(b)
on March 4, 1993.
During the course of the audit of petitioner's
individual income tax returns for 1989 and 1990,
respondent's revenue agent discovered that the Internal
Revenue Service had no record of having received returns
from Friedmann Financial Number 2, Friedmann Investors
Number 1, or Friedmann Investors Number 2 for taxable year
1989. During a meeting with respondent's agent, petitioner
signed copies of the 1989 Forms 1065, U.S. Partnership
Return of Income, for Friedmann Financial Number 2 and
Friedmann Investors Number 2.
Petitioner's individual return for 1989 reports wages,
salaries, tips, etc. of $72,252. Attached to the return is
a Form W-2, Wage and Tax Statement, that reports wages of
$24,252 from an employer, Dr. Carey Strom, who is also a
client of petitioner's Schedule C business, as discussed
further below. Petitioner's 1989 return also reports wages
of $48,000 from Friedmann Management Corp.
There is attached to petitioner's return for both 1989
and 1990 a Schedule C, Profit or Loss From Business, for a
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