Howard and Linda Levine - Page 5




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               On their late-filed joint Federal income tax returns,                  
          petitioners reported Schedule C, Profit or Loss From Business,              
          income and Form 1099 income relating to petitioner’s work as a              
          bookkeeper and tax return preparer for his father’s accounting              
          firm and relating to petitioner’s work as a seller of insurance             
          and alarm systems.                                                          
               Petitioners did not report on the above late-filed joint               
          Federal income tax returns income petitioner had received for               
          bookkeeping and tax return preparation services petitioner had              
          rendered for his own clients.                                               
               Petitioners made no payments with the above late-filed tax             
          returns.                                                                    
               On audit for 1990 through 1993, utilizing specific items of            
          income that had been deposited by petitioner into bank accounts,            
          the existence of which accounts petitioner had not disclosed to             
          respondent’s representatives, respondent determined that                    
          petitioners had not reported on the above Federal income tax                
          returns the income petitioner had received from the bookkeeping             
          and tax return preparation services petitioner had rendered for             
          his own clients.                                                            
               The schedule below reflects the total net business income              
          reported on petitioners’ joint Federal income tax returns for               
          1990, 1991, 1992, and 1993, as late filed on January 5, 1996, the           
          income that was earned by petitioner for bookkeeping and tax                






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