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The examination of petitioner’s returns for the years in
issue began in 1996.1 Petitioner failed to report interest
income, rental income, dividend income, and capital gains on his
original returns. On May 7, 1997, petitioner filed Forms 1040X,
Amended U.S. Individual Income Tax Return, for 1993, 1994, and
1995. On the amended returns, petitioner reported additional
income as follows:
1993 1994 1995
Interest income $869 $133 $449
Sch. E net income 199 2,137 677
Dividend income 777 2,377 2,844
Capital gain 1,547 1,518 22,898
Sch. C net income 1,715 --- ---
Total $5,107 $6,165 $26,868
On each amended return, petitioner indicated that he had
“inadvertently omitted” these items of income.
On an application to open an investment account in 1993,
petitioner indicated that his income for that year was between
$30,000 and $49,999. On an application for a credit card that
petitioner applied for in 1995 he indicated that his monthly
gross income from Grand Video was $7,000.
Revenue Agent Keinle (Agent Keinle) conducted the
examination of petitioner’s returns. During the course of the
examination, petitioner provided her with business and personal
1 The provisions of sec. 7491 are not applicable to this
proceeding.
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