John F. Moran - Page 4

                                        - 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

Last modified: May 25, 2011