Walter L. Medlin - Page 87

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          did not disclose all his installment sale activities to the                 
          revenue agent during this examination.  Petitioner also informed            
          the revenue agent that his Cayman Islands trust account had been            
          closed in 1983.  However, petitioner received five checks                   
          totaling $135,000 from the Cayman Islands trust in 1985.  On                
          October 21, 1988, petitioner agreed to income tax deficiencies of           
          $10,550 and penalties of $3,584 for those tax years.                        
               Respondent received Forms 1040 for petitioner’s 1985 and               
          1986 tax years on November 29, 1988.  Those forms were not timely           
          filed.13  Petitioner’s Form 1040 for 1987 was received on October           
          17, 1988.  Petitioner was given an extension until October 16,              
          1989, to file his 1988 Federal income tax return.  Petitioner did           
          not file his Form 1040 for 1988 until April 26, 1990.  For each             
          of his Forms 1040 for 1985, 1986, 1987, and 1988, petitioner                
          listed his address as “P.O. Box 383, Lake Lure, NC 28746”.                  
          However, petitioner actually resided in Kissimmee, Florida, at              
          the time he filed his returns.                                              
               Respondent examined petitioner’s 1985, 1986, 1987, and 1988,           
          tax returns.  As part of that examination, respondent’s revenue             
          agent spent several weeks researching courthouse records in seven           
          counties in order to identify petitioner’s real estate                      


               13Petitioner claims to have previously filed timely returns            
          for 1985 and 1986; however, respondent could not find those                 
          purported returns.  Petitioner did not produce copies of any such           
          returns, and he did not present any evidence or testimony on the            
          subject of those purported returns.                                         




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