Gary M. Dashiell and Frances J. Dashiell - Page 2

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                                     Background                                       
               During 1997 and at the time their petition was filed,                  
          petitioners resided in Multnomah County, Oregon.                            
               On May 7, 1998, petitioners filed with respondent a document           
          purporting to be their 1997 joint Federal income tax return (1997           
          tax return).  Thereon, petitioners indicated that Gary’s                    
          occupation was that of a salesman and that Frances’s (Fran)                 
          occupation was that of a computer consultant.                               
               A Form W-2, Wage and Tax Statement, that was attached to               
          petitioners’ 1997 tax return reflected that in 1997 Gary received           
          wages of $25,101 from his employer and that during 1997 $2,114 in           
          Federal income taxes was withheld from Gary’s wages.                        
               There was no Form W-2 attached to and no Schedule C, Profit            
          or Loss From Business, or estimated tax payments reflected on               
          petitioners’ 1997 tax return relating to wages or income earned             
          in 1997 by Fran.                                                            
               In spite of the above $25,101 in Gary’s wages and in spite             
          of any income Fran earned from her computer consulting business,            
          on their 1997 tax return, petitioners reflected zero wages, zero            
          total income, zero adjusted gross income, zero taxable income,              
          and zero tax liability.  Also, on their 1997 tax return                     
          petitioners claimed a refund for the total $2,114 in Federal                
          income taxes that had been withheld from Gary’s wages.                      







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