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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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