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2. Petitioner’s 1987 and 1988 Returns
Petitioner did not report income from the 1987 and 1988 NSA
checks issued to Camaro on his 1987 and 1988 returns or 1987 and
1988 amended returns.
Petitioner filed his 1987 return on October 19, 1988, and
his amended 1987 return on May 15, 1989. Petitioner filed his
1988 return on September 28, 1989, and respondent received his
amended 1988 return on January 22, 1990.
3. TCM’s 1987 and 1988 Returns
TCM did not report income from the 1987 and 1988 NSA checks
issued to Camaro on its 1987 and 1988 tax returns. TCM
overstated its deductions by $6,359 on its 1988 return.
Petitioner signed and filed all of TCM’s tax returns.
J. Petitioners’ Indictments and Guilty Pleas
In March 1997, petitioner, TCM, and Camaro were indicted by
a grand jury on several counts. Petitioner pled guilty to making
a false statement on a 1992 loan application, and TCM pled guilty
under section 7206(1) to filing a false amended income tax return
for 1988.
K. Statute of Limitations and Petition To Quash Summons
1. Proceedings in the U.S. District Court for the Northern
District of Alabama
On October 4, 1990, respondent served nine third-party
administrative summonses relating to petitioners’ and Camaro’s
tax liabilities for the 1983 through 1989 tax years. Petitioners
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