Douglas W. and Gail Caple - Page 5




                                        - 4 -                                         
          Ashley’s care that were not otherwise covered by their                      
          insurance.4                                                                 
          Petitioners’ 1993 and 1994 Taxable Years                                    
               In taxable years 1993 and 1994, petitioners sold Wal-Mart              
          stock for $57,400 and $56,650, respectively.  Petitioners failed            
          to report the proceeds from either sale on their 1993 or 1994               
          Federal income tax return.                                                  
               Respondent commenced an examination of petitioners’ 1993 and           
          1994 Federal income tax returns.  Following notice that these               
          returns had been selected for examination, petitioners promptly             
          contacted respondent’s Appeals Office; they were unable to reach            
          a mutually satisfactory resolution to the matter of petitioners’            
          unreported income.                                                          
               On December 6, 1996, respondent sent petitioners a notice of           
          deficiency for taxable years 1993 and 1994.  The notice of                  
          deficiency was sent to petitioners’ current address, and it                 
          informed petitioners of their right to file a petition for                  
          redetermination with the Court no later than 90 days from the               
          date of mailing.  Petitioners filed a petition with the Court on            
          July 8, 1997, citing a series of “extra-ordinary [sic]                      
          circumstances that prevented [them] from filing” before the 90-             

               4 Aside from petitioners’ testimony regarding Ashley’s                 
          various medical conditions, and proof of their insurance, the               
          record is devoid of any evidence substantiating the costs                   
          petitioners actually incurred with respect to Ashley’s medical              
          expenses.                                                                   






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