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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Other facts have been deemed admitted pursuant to Rule 90(c).
At the time they filed the respective petitions in these
cases, Ms. Dimon and Mr. Dimon, who were married throughout the
entire taxable year 1996, resided in Irvine, California.
Neither Ms. Dimon nor Mr. Dimon filed a tax return (return)
for taxable year 1996. On January 10, 2002, petitioners provided
to respondent an original, signed Form 1040, U.S. Individual
Income Tax Return, for 1996 (unfiled Form 1040). Petitioners
included Schedule C, Profit or Loss From Business (Schedule C),
in that unfiled Form 1040. In Schedule C of the unfiled Form
1040 for 1996, petitioners indicated that during 1996 Mr. Dimon
was the proprietor of an executive recruiting business. Schedule
C of the unfiled Form 1040 for 1996 showed gross receipts of
$127,970 and claimed expenses of $57,064.
Neither Ms. Dimon nor Mr. Dimon made any estimated or other
tax payments for 1996 except for $94 which was withheld from Ms.
Dimon’s wages.
During 1996, Mr. Dimon received $127,970 in nonemployee
compensation.
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Last modified: May 25, 2011