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testimony to explain the documentation. Petitioner did not offer
into evidence any documentation of her business income and
expenses for 1984-86.
VII. Late Filing of Petitioner’s 1987-90 Returns
Petitioner filed her 1987 return on August 26, 1992, having
requested and received two extensions, the second of which
expired on October 15, 1988. Petitioner and Rowe filed their
1988 joint return on August 27, 1992, and their 1989 and 1990
joint returns on August 25, 1992. Neither petitioner and Rowe
nor Mr. Aunan requested extensions of time to file the 1988-90
returns.
For each year at issue, petitioner gathered, organized, and
summarized her Schedule C information and delivered it to Mr.
Aunan for his use in preparing that year’s return. For the
1988-90 years, however, petitioner did not actually deliver her
Schedule C information to Mr. Aunan until after the return due
dates. After petitioner submitted her Schedule C information to
Mr. Aunan, she followed up by asking him periodically what
additional information he needed to complete the returns. Mr.
Aunan normally responded with more requests for information;
within a day or two, petitioner would supply the requested
information to him. In 1992, petitioner “threatened” Mr. Aunan,
and the returns for all 4 years were finally completed and filed
in August of that year.
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