James Luther Cochrane - Page 7

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          'United States' in order to specify any of several possible                 
          definitions applicable to these terms."                                     
               (4) In request 6, respondent asserted that petitioner did              
          not receive any income from sources outside the United States               
          during the years in issue.  In response, petitioner stated that             
          "respondent does not cite statute and its implementing regulation           
          defining the terms 'income' or 'United States' used in the                  
          allegation."                                                                
               (5) In request 10, respondent asserted that petitioner                 
          reported on his tax returns for 1983 through 1985 that certain              
          wages were excluded from gross income as income earned while                
          physically present in a foreign country during the entire 12                
          months of the taxable year.  In response, petitioner contended              
          that the "Statements are presumptive of law and are not facts               
          susceptible to admission or denial by petitioner."  In addition,            
          petitioner stated that "respondent does not define the term                 
          'wages' or the term 'taxable years' used in reference to                    
          petitioner in this case" and that "respondent fails to identify             
          any * * * authority for establishing California [as a] state                
          under federal revenue jurisdiction."                                        
               (6) In requests 15 through 17, respondent asserted that                
          during 1984 through 1986, petitioner conducted a tax return                 
          preparation and tax counseling business and that petitioner                 
          received, but failed to report, fees in 1984, 1985, and 1986.               
          Respondent listed the names of specific payors and the amounts              




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