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Specifically with regard to the years at issue herein, on
December 1, 1994, Alimam untimely mailed to respondent petitioner
and Alimam’s 1993 joint Federal income tax return on which return
petitioner and Alimam’s total joint Federal income tax liability
was reflected as $72,991 and on which return the only taxes shown
as paid were the $20,302 that petitioner had paid through income
tax withholding.
On September 15, 1995, Alimam untimely mailed to respondent
petitioner and Alimam’s 1994 joint Federal income tax return on
which return petitioner and Alimam’s total joint Federal income
tax liability was reflected as $52,902 and on which return the
only taxes shown as paid were the $21,711 that petitioner had
paid through income tax withholding.
On June 4, 1996, Alimam timely mailed to respondent
petitioner and Alimam’s 1995 joint Federal income tax return on
which return petitioner and Alimam’s total joint Federal income
tax liability was reflected as $43,260 and on which return the
only taxes shown as paid were the $23,221 that petitioner had
paid through income tax withholding.
Petitioner did not meet Alimam’s accountant until sometime
in 1996 soon after which petitioner and Alimam separated.
Petitioner and Alimam’s joint Federal income tax returns for
1993, 1994, and 1995 were accurately prepared by Alimam’s
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