Silvia S. Rodriguez - Page 9

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               1.   Whether Petitioner Had Filed All Required Tax Returns             
               Petitioner testified that she filed original income tax                
          returns for 1991-2000 with the Philadelphia Service Center.  We             
          are not persuaded by her testimony.  The parties stipulated the             
          admission into evidence of respondent’s Form 2866, Certificate of           
          Official Record, which states that respondent has no record of              
          petitioner’s having filed income tax returns for tax years 1988-            
          2000.  Fast and Neighbor both testified that they searched                  
          respondent’s records.  Fast found that respondent had no record             
          that petitioner had filed returns for 1991-95.  Neighbor found              
          that respondent had no record that petitioner had filed returns             
          for 1991-98.  Respondent’s certificate of official record and the           
          testimony of Fast and Neighbor were more persuasive in showing              
          that petitioner had not filed returns for 1988-2000 than                    
          petitioner’s testimony and the copies of some of her returns were           
          in showing that she had.  Thus, we find that petitioner did not             
          file returns for 1988-2000.                                                 
               Petitioner contends that respondent erred in not filing the            
          copies of the returns for 1991, 1992, 1993, and 1996 that she               
          gave to Fast and Neighbor.  We disagree.  Those returns did not             
          include petitioner’s original signature.  Sec. 6061(a); Beard v.            
          Commissioner, 82 T.C. 766 (1984), affd. 793 F.2d 139 (6th Cir.              
          1986); sec. 1.6061-1(a), Income Tax Regs.  Petitioner did not               
          provide copies of her returns for 1990, 1994, 1995, 1997, 1998,             






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