Howard and Linda Levine - Page 6




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          return preparation services that was not reported on petitioners’           
          late-filed Federal income tax returns, and petitioners’ total               
          corrected net business income for each year, as well as                     
          petitioners’ Federal income tax liabilities as reported.4                   
          Respondent made no adjustments to the expenses claimed on                   
          petitioners’ late-filed joint Federal income tax returns, and               
          petitioners have submitted no credible evidence as to their                 
          entitlement to additional expenses.                                         

                 Net Business                                  Tax                   
                  Income Reported Omitted      Corrected        Liability             
             Year      On Return      Income   Net Business IncomeReported             
             1990      $43,548   $ 5,800        $49,348        $10,762                
             1991      31,367    16,200         47,567         7,428                  
             1992      16,435    28,968         45,403            2,339               
             1993      16,605    42,825          59,530              2,346            


               On August 11, 2000, petitioner pled guilty in Federal District         
          Court to one count of a four-count felony indictment under section          
          7201 for income tax evasion relating to petitioners’ Federal income         
          tax returns for 1990 through 1993.  Petitioner’s guilty plea                
          related to 1993.                                                            






          4  Due to settlement of a number of adjustments, petitioner’s               
          corrected Federal income tax liabilities for each of the years in           
          issue will be determined in a Rule 155 computation.                         





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