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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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