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Background
The parties submitted the instant case, fully stipulated,
without trial, pursuant to Rule 122. The parties’ stipulations
of fact are hereby incorporated by this reference and are found
as facts in the instant case.
Petitioners are husband and wife, filed joint Federal income
tax returns for their 1989, 1990, 1991, 1992, and 1993 taxable
years, and were residents of Springfield, Missouri, when they
filed their petitions. During the years in issue, petitioner was
a self-employed criminal defense lawyer. Prior to private
practice, petitioner served as an Assistant United States
Attorney. Petitioner maintained the records for both his
personal and law firm accounts. Petitioners employed the cash
method of accounting in determining the income and expenses
reported on their joint Federal income tax returns for the years
in issue.
Petitioners filed original and amended Federal individual
income tax returns, Forms 1040 and 1040X, as follows:
Year Description Date Filed
1989 Tax return 4/15/1990
1989 1st amended return 1/30/1995
1989 2nd amended return 2/15/1995
1989 3rd amended return 7/22/1996
1990 Tax return 4/15/1991
1990 1st amended return 8/8/1994
1990 2nd amended return 1/24/1995
1990 3rd amended return 7/22/1996
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Last modified: May 25, 2011