- 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 aPage: 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