- 4 - (11) whether the statute of limitations bars the assessment and collection of the deficiencies in tax, additions to tax, and penalties that respondent has determined against petitioner for 1988, 1989, and 1990. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts, the second stipulation of facts, and the attached exhibits2 are incorporated herein by this reference. Petitioner resided in Williamstown, New Jersey, when he filed his petition in this case. During the years in issue, petitioner was married to Bonnie E. McNamara (formerly Bonnie E. Moran). Petitioner and Bonnie E. McNamara (Ms. McNamara) maintained a personal joint checking account at Continental Bank during the years in issue. Petitioner and Ms. McNamara are now divorced. Ernest Agresto, a certified public accountant, prepared petitioner and Ms. McNamara’s joint income tax returns for the years in issue. Mr. Agresto prepared these returns using information supplied by Ms. McNamara. With petitioner’s permission, Ms. McNamara signed petitioner’s name on their joint 2 Respondent has objected on the grounds of relevancy and/or hearsay to the admission of the following exhibits: 176-P through 179-P, 183-P through 215-P, 222-P, 223-P, 227-P through 230-P, 232-P through 235-P, 237-P, 238-P, 243-P, and 244-P. At trial, we reserved ruling on these exhibits. We have considered each of the exhibits in question and find that they do not justify any alteration in our findings of fact.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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