-2- OPINION KROUPA, Judge: Respondent determined a $4,428 deficiency in petitioner’s Federal income tax for 1999 and a $7,784 deficiency in petitioner’s Federal income tax for 2000. We are asked to decide for the first time whether the limitations period for assessing income tax under section 6501(c)(1)1 is extended if the tax on a return is understated due to the fraudulent intent of the income tax return preparer. We conclude that it is. Background This case was submitted fully stipulated under Rule 122. The stipulation of facts and the accompanying exhibits are incorporated by this reference. Petitioner lived in Memphis, Tennessee, at the time he filed the petition. Petitioner, a truck driver for UPS during 1999 and 2000, timely filed his returns for 1999 and 2000 (the years at issue). Petitioner gave his Form W-2, Wage and Tax Statement, section 401(k) statement, mortgage interest statement, and property statements to Gregory D. Goosby (Mr. Goosby), who prepared petitioner’s returns for the years at issue and filed them with respondent. Mr. Goosby prepared petitioner’s returns for the years at issue and claimed false and fraudulent Schedule A, Itemized Deductions, for both years. The false deductions included 1All section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011