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Background
The facts in this case have been established by the Court’s
Order of March 10, 2005.1 At the time of filing the petition,
petitioner resided in Fort Worth, Texas.
Petitioner worked as a contractor for Tuttle Roofing during
the 1998, 1999, 2000, and 2001 taxable years. Tuttle roofing
paid petitioner $133,339 during 1998, $88,450 during 1999,
$117,905 during 2000, and $137,000 during 2001. Petitioner also
earned $96 in savings bond interest from Nationsbank in 1998.
Petitioner did not make estimated tax payments, have tax
withheld, or file a Form 1040, U.S. Individual Income Tax Return,
for any of the taxable years 1998, 1999, 2000, or 2001.
On April 19, 2004, respondent prepared, pursuant to section
6020(b), four substitute returns for petitioner after petitioner
failed to comply with respondent’s requests to file returns for
the four years in issue. On June 18, 2004, respondent mailed to
petitioner at his last known address, 1216 Warden Street, Fort
Worth, Texas 76126, four statutory notices of deficiency
asserting deficiencies and additions to tax under sections
1 On Jan. 25, 2005, respondent filed a Motion to Show Cause
Why Proposed Facts in Evidence Should Not be Admitted as
Established pursuant to Rule 91(f). On Jan. 27, 2005, we granted
respondent’s motion and further ordered petitioner to file a
response in compliance with Rule 91(f)(2) or respondent’s
proposed stipulations would be deemed established and an order
would be entered pursuant to Rule 91(f)(3). Petitioner never
responded to our order, and we, accordingly, ordered the facts
deemed established on Mar. 10, 2005.
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