Gerard and Audrey Kathleen Hennessey - Page 8




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          cash or paid her various expenses.4  Petitioners did not maintain           
          any receipts or other documentary evidence with respect to the              
          amounts paid to, or on behalf of, their daughter.                           
          I.  Federal Income Tax Returns                                              
               A.  Petitioners’ Individual Tax Returns                                
               Some time prior to the end of 1993, petitioners sent to the            
          Internal Revenue Service (IRS) a joint Form 1040, U.S. Individual           
          Income Tax Return, for 1992.  That document had “Estimated”                 
          written on the top of the first page (1992 “Estimated” return).             
          Petitioners testified that they prepared and sent the 1992                  
          “Estimated” return in that manner because they were not in                  
          possession of all their supporting documents and therefore were             
          not able to determine the exact amounts to be reported on the               
          return.                                                                     
               On or about August 12, 1994, petitioners sent to the IRS an            
          unsigned Form 1040 for the 1993 taxable year.  Petitioners had              
          written “Estimated” on the top of the first page of the unsigned            
          1993 return (1993 “Estimated” return).  The 1993 “Estimated”                
          return did not have any attached schedules or forms.                        
               Petitioners claimed that they were unable to file a final              
          tax return for either 1992 or 1993 prior to the end of 1994 due             
          to time restraints from their various work responsibilities,                


               4 For example, on their 1994 return, petitioners deducted              
          $17,874 for payments made to, or on behalf of, their daughter.              






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