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Further trial is necessary to resolve the remaining issues
in this case. Unless otherwise specified, section references are
to the Internal Revenue Code in effect for the applicable years,
and Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Maryland when he filed the petition.
An accounting firm prepared petitioner’s tax returns for 1981-95.
B. Petitioner’s Delivery of Tax Returns to Respondent’s Offices
On February 20, 1997, petitioner signed income tax returns
for 1981-95 (original returns with original signatures). After
he signed those returns, he photocopied them and signed them in
blue ink over his photocopied signatures (photocopied returns
with original signatures).
Petitioner prepared a letter of transmittal addressed both
to Paul M. Harrington (Harrington), Baltimore’s District
Director, and Elizabeth S. Henn (Henn), in the Baltimore office
of District Counsel. Petitioner’s letter stated:
Dear Mr. Harrington and Mrs. Henn,
I am delivering to District Counsel with this
letter original filings of 1040 tax returns for the
year 1981 and for each year thereafter up through and
including 1995. My attorney, Mr. Jeffrey Dickstein,
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