E. Carolyn Mellen - Page 7




                                                - 7 -                                                   
            of the taxable years 1994 (1994 joint return)4 and 1995 (1995                               
            joint return).5                                                                             
                  At times that are not disclosed by the record, petitioner                             
            prepared, without the aid of a paid return preparer, and filed                              
            returns using married filing separate status for the taxable                                
            years 1992, 1993, and 1996 through 2000, respectively.  Sometime                            
            between September 28, 2001, and April 18, 2002, petitioner                                  
            prepared, without the aid of a paid return preparer, a return                               
            using head of household status for taxable year 2001 (2001                                  
            return), but did not sign or file that return.6                                             
                  The 1994 joint return reported, inter alia, adjusted gross                            
            income of $19,815, taxable income of $0, compensation of $19,788                            
            that petitioner received from Questar, taxable interest income of                           
            $2, and dividend income of $25.                                                             
                  The 1995 joint return reported, inter alia, adjusted gross                            
            income of $355,340, taxable income of $315,704, compensation of                             
            $22,691 that petitioner received from Questar, taxable interest                             

                  4Petitioner and Mr. Mellen applied for and received exten-                            
            sions until Oct. 15, 1995, within which to file the 1994 joint                              
            return.                                                                                     
                  5Petitioner and Mr. Mellen applied for and received exten-                            
            sions until Oct. 15, 1996, within which to file the 1995 joint                              
            return.                                                                                     
                  6In the 2001 return, petitioner claimed Schedule A itemized                           
            deductions of $3,051 for State and local income taxes, $3,106 for                           
            real estate tax, $150 for personal property tax, $691 for mort-                             
            gage interest, $3,775 for gifts to charity, and $3,000 for                                  
            attorney and accounting fees.                                                               





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