-3- deductions for charitable contributions, meals and entertainment, and pager and computer expenses, as well as various other expenses. Petitioner received complete copies of petitioner’s returns for the years at issue after they had been filed, but he did not file an amended tax return for either year. Two special agents of respondent’s Criminal Investigation Division interviewed petitioner concerning Mr. Goosby’s preparation of his income tax returns. Mr. Goosby was indicted, tried, and convicted of 30 violations of section 7206(2) (willfully aiding and assisting in the preparation of false and fraudulent income tax returns) in 2006, although petitioner’s returns for the years at issue were not used as the basis for any counts of the indictment. Respondent issued a deficiency notice to petitioner on March 22, 2005, in which respondent disallowed numerous Schedule A deductions petitioner claimed on his returns for each of the years at issue. The deficiency notice did not assert the fraud penalty under section 6663 against petitioner. The regular 3- year limitations periods for assessment of taxes with respect to petitioner’s returns for the years at issue expired on April 15, 2003, and April 15, 2004, respectively. Petitioner timely filed a petition. Petitioner has conceded all adjustments respondent made in the deficiency notice other than one adjustment respondent concedes was made in error. The parties agree that the false deductions on petitioner’s income tax returns for the years atPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011