- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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