- 6 -
financial assistance to their children and fully paid for their
children to attend undergraduate and graduate schools, including
medical school for Nan and law school for Karen.
Petitioner and Dr. Alt filed their tax returns for the years
1982 to 1988 with a filing status of “Married filing joint
return” (joint return). Respondent treated the tax return for
1989 as if Dr. Alt filed the return with a filing status of
“Married filing separate” because petitioner did not sign the
return. Respondent has no records indicating that petitioner
filed a tax return for 1989. Petitioner chose not to review the
tax returns prior to signing them, even though she was aware of
past problems with the IRS. Dr. Alt never forced petitioner to
sign the tax returns and never abused petitioner.
On April 5, 1989, respondent sent to petitioner and Dr. Alt
a notice of deficiency for the 1985 taxable year. Respondent’s
adjustments giving rise to the deficiency resulted largely from
disallowed deductions. Respondent also determined that
petitioner and Dr. Alt were liable for additions to tax for
negligence and substantial understatement of tax.
On October 10, 1991, respondent sent to petitioner and Dr.
Alt a notice of deficiency for the 1982, 1983, 1984, 1986, 1987,
and 1988 taxable years.3 Respondent determined that amounts
3 On the same date, respondent also sent to petitioner and
Dr. Alt a notice of deficiency regarding increases in the
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011