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his accountants. Consequently, petitioner did not know “what the
rent was, how much was paid [for] materials, supplies, and stuff”
with regard to the financial operations of the company.
Federal Income Tax Returns
Petitioners filed joint Federal income tax returns for 1993,
1994, and 1995. Dormer & Louver was operated as a sole
proprietorship; for Federal income tax purposes, the income and
expenses of the business were reported on Schedule C, Profit or
Loss From Business (Sole Proprietorship). On the Schedules C,
petitioner described the principal business of Dormer & Louver as
“MANUFACTURING CONSTRUCTION MATERIALS”.
Petitioners failed to file their 1993-95 tax returns timely.
They did not request extensions of time to file their income tax
returns for any of these years.
On an undisclosed date in 1996, petitioners filed for
bankruptcy. Petitioners filed joint income tax returns for 1993-95
after they filed for bankruptcy.
Petitioners’ joint returns for 1993 and 1994 were prepared by
Accufast Business Services, Inc. (Accufast), of Palmdale,
California. The 1993 and 1994 returns were signed by Accufast on
April 1, 1994, and April 12, 1995, respectively. Both of these
returns were signed by petitioners on September 12, 1995. The
returns were received by respondent’s Ogden/Las Vegas Service
Center on September 16, 1996.
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