Anthony Tinsman - Page 10




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          independent investigation" by the IRS in all unreported income              
          cases.  Parker v. Commissioner, 117 F.3d 785, 787 (5th Cir.                 
          1997), affg. per curiam an Order of this Court.  Where a taxpayer           
          does not dispute that he received the payment in question as                
          reported on a third-party information return, the Commissioner              
          has no duty to investigate.  See id.  And where the taxpayer                
          fails to dispute a connection with the tax-generating income, the           
          "naked assessment" doctrine does not apply.  See Parrish v.                 
          Commissioner, 168 F.3d 1098, 1100-1101 (8th Cir. 1999), affg.               
          T.C. Memo. 1997-474; Day v. Commissioner, 975 F.2d 534, 537 (8th            
          Cir. 1992), affg. in part and revg. in part on another issue T.C.           
          Memo. 1991-140; Zuhone v. Commissioner, 883 F.2d. 1317, 1326 (7th           
          Cir. 1989), affg. T.C. Memo. 1988-142; Andrews v. Commissioner,             
          T.C. Memo. 1998-316.                                                        
               Petitioner denies in his trial memorandum that he was an               
          "'employee,' engaged in 'employment' or 'self-employment'" in               
          either 1994, 1995, or 1996 or that he received "'wages' or 'non-            
          employee compensation'" in those years.  Considering petitioner's           
          legal arguments and the evidence in the record in this case, we             
          interpret his use of quotation marks around words such as                   
          "employee" and "wages" to mean that petitioner uses those terms             
          in a personal way that has a special meaning to him, not as they            
          are ordinarily understood.                                                  








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