- 3 - Federal income tax returns for 1991 and 1992 on August 11, 1994, and March 21, 1994, respectively--much more than 5 months after their respective due dates. Petitioner understated the proper tax due on his Federal income tax return for 1991 by $17,939 and for 1992 by $1,395. This constituted an understatement of the proper tax due of approximately 97 percent for 1991 and 70 percent for 1992. Tesco Driveaway, Inc. (Tesco), was incorporated under the laws of the State of Missouri on November 15, 1991. Prior to the incorporation, petitioner operated the Tesco business as a sole proprietorship. Prior to August 1, 1991, petitioner asked his personal and business accountant, Dal Livingood, owner of Diversified Management Services, to prepare the necessary documentation to incorporate Tesco. At petitioner’s direction, Mr. Livingood prepared and submitted incorporation papers for Tesco to the Missouri secretary of state on or about August 1, 1991. The Missouri secretary of state returned the incorporation papers unfiled due to some defect. Mr. Livingood remedied the defect in the incorporation papers, obtained petitioner’s signature on the revised incorporation papers, and resubmitted them. The Missouri secretary of state accepted the resubmitted documents, and Tesco was incorporated on November 15, 1991. Petitioner failed to include on Schedule C of his 1991 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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