- 7 -
to answer any of their questions, they informed him that the
meeting was concluded and asked him and the individuals who
accompanied him to leave. After the September 1995 meeting,
petitioner sent a letter to the revenue agent's supervisor
complaining that he had been denied due process. Petitioner did
not provide to the Service at the September 1995 meeting, or at
any other time, any documents or information from which his tax
liability could be determined for the years for which he did not
file returns.
The Service's audit of petitioner continued from August 1995
through October 1996. That audit took significantly longer than
that type of audit should have taken because petitioner refused
to cooperate with the revenue agent or any other representatives
of the Service. As a result of petitioner's refusal to cooperate
with the Service, the Service had to conduct an extensive in-
vestigation in order to determine petitioner's income for each of
the years at issue and other information relevant to determining
his tax liability for each such year.
On February 19, 1988, petitioner acquired his residence
located at 5136 Neponset Avenue, Orlando, Florida (Neponset
property) for $98,000. In acquiring that property, petitioner
obtained on February 19, 1988, a mortgage loan from the Cal-
ifornia Federal Savings and Loan Association in the amount of
$78,400. During 1992, petitioner paid principal and interest
totaling $24,983 on the mortgage loan on the Neponset property,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011