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answer to the Basiles’ petition also included the following
allegations in support of the timeliness of the Basiles’ notice
of deficiency for 1996:
(a) The petitioners’ joint income tax return for
the taxable year 1996 was filed on October 14, 1997.
(b) The amount of gross income stated in the
income tax return filed by the petitioners for the
taxable year 1996 was $115,600.
(c) During the taxable year 1996, the petitioners
received additional income of $602,514 from their
chiropractic practice through corporations or trusts
which should be disregarded as sham entities * * *.
Said amount of additional income was not included in
the gross income stated in the return filed by
petitioners for the taxable year 1996, and there was
not disclosed on the return or in a statement attached
thereto the fact that such amount was received during
said year.
(d) Petitioners did not borrow or receive from
nontaxable sources any funds, or other assets, not
properly taken into account by the respondent which
would cause or account for the additional income as set
forth above.
(e) The additional gross income that petitioners
received and that was omitted from the income tax
return they filed for the taxable year 1996 is in
excess of 25 percent of the gross income reported in
such return.
(f) The notice of deficiency setting forth the
respondent’s determination of the deficiencies for the
taxable year 1996 was timely sent to the petitioners by
certified mail on October 12, 2001, which date was
prior to the expiration of the six-year period for
assessment applicable under I.R.C. � 6501(e)(1)(A).
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