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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
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