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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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