Walter L. Medlin - Page 9

                                        - 9 -                                         
          reported on the returns reflected deposits into petitioner’s bank           
          accounts, less any deposits that were classified as loan                    
          proceeds.  Any amounts not deposited into petitioner’s bank                 
          accounts were not reported as income.  Petitioner did not provide           
          Mr. Kelly with checks, real estate contracts, real estate closing           
          statements or any other books or records to prepare his income              
          tax returns.  Petitioner did not inform Mr. Kelly that the                  
          proceeds from his real estate sales were deposited in Mr. Miles’s           
          law firm’s trust account, and those proceeds were not reflected             
          on the spreadsheets.  Petitioner did not inform Mr. Kelly of any            
          additional income.  Throughout the 1980s and 1990s, petitioner              
          asked Mr. Kelly questions about the requirements for like-kind              
          exchanges.                                                                  
               Petitioner requested extensions for the filing of his income           
          tax returns for 1985, 1986, 1987, and 1988.  Petitioner’s Form              
          2688, Application for Extension of Time to File U.S. Individual             
          Income Tax Return, for the 1985 tax year states as his need for             
          an extension:  “Client derived substantially all his income from            
          a bulk land transaction, which was extremely complex.  Additional           
          time is needed to analyze the transaction.”  Petitioner did not             
          provide any information to Mr. Kelly regarding any bulk land sale           
          transaction.  Petitioner requested an extension for tax years               
          1986, 1987, and 1988, because “Taxpayer has not received all                
          needed K-1's for 1065 & 1120 tax returns that represent a                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011