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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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Last modified: May 25, 2011