Larry J. and Patricia A. Sumrall - Page 5




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          Residence                                                                   
               At the time of the petition, petitioners resided in Reno,              
          Nevada.                                                                     
          Returns                                                                     
               Petitioners did not timely file Federal income tax returns             
          for any of the audit years (1987 through 1991) or for 1992 and              
          1993.                                                                       
               In early 1993, the Internal Revenue Service (IRS) initiated            
          a criminal tax investigation (the criminal investigation) of                
          petitioner husband (petitioner), with respect to the audit years.           
               On July 13, 1993, petitioners filed their Federal income tax           
          returns with respondent for the audit years.  Those returns show            
          tax liabilities as follows:                                                 
                              Year           Liability                                
                              1987           $1,841                                   
                              1988           12,395                                   
                              1989           10,251                                   
                              1990           14,487                                   
                              1991           9,942                                    
               Petitioners requested an extension of time to file their               
          Federal income tax return for 1992.  Respondent approved the                
          request and extended the due date for the 1992 return to                    
          October 15, 1993.  Petitioners made a joint return of Federal               
          income tax for 1992 by filing a Form 1040, U.S. Individual Income           
          Tax Return (the 1992 return), with the Internal Revenue Service             
          Center in Ogden, Utah (the Ogden Service Center), on October 7,             
          1996.  Among the attachments to the 1992 return is a single page,           





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