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By letter dated September 27, 2002 (September 27, 2002
letter), a certified public accountant representing petitioner
and his spouse (petitioner’s C.P.A.) sent to petitioner Form 1040
that he had prepared on behalf of petitioner and his spouse for
their taxable year 1999 (petitioner’s 1999 return). Petitioner’s
C.P.A.’s September 27, 2002 letter, inter alia, gave petitioner
instructions regarding filing the 1999 return. That letter
stated in pertinent part:
Enclosed are two copies of your 1999 federal income tax
return. One copy is for your records. Send the other
copy to the Internal Revenue Service. Please sign and
date the tax returns at the bottom of Form 1040, page
2.
Your Federal taxes have been paid in full. Do not
include a check. Mail your Federal return, on or
before April 17, 2000[5] to:
INTERNAL REVENUE SERVICE CENTER
Austin, TX * * *
We recommend that you send the returns using certified
mail or other delivery service with postmarked re-
ceipts.
At a time not disclosed by the record before February 24,
2003, petitioner filed petitioner’s 1999 return that petitioner’s
C.P.A. had prepared. Petitioner’s 1999 return showed a business
loss of $82,592 from Schedule C, Profit or Loss From Business
(Schedule C), and negative total income and negative adjusted
5The date of Apr. 17, 2000, for filing petitioner’s 1999
return that was stated in petitioner’s C.P.A.’s September 27,
2002 letter was wrong. As noted above, petitioner’s C.P.A. did
not send petitioner’s 1999 return to petitioner until around
Sept. 27, 2002.
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Last modified: May 25, 2011