Raymond E. Vogt, Jr. - Page 5




                                         -5-                                          
          for 2001 and 2002, and therefore was liable for increased                   
          deficiencies, increased penalties under section 6663, and                   
          increased additions to tax under section 6651(a)(1).5  On                   
          November 15, 2006, trial was held in San Francisco, California.             
               During the years at issue, petitioner was an employee of               
          Linotext America, Inc., and self-employed as a printing salesman            
          doing business as Ray Vogt Enterprises and Springboard Ltd.                 
          Trust.  Petitioner created Springboard Ltd. Trust during 2002 to            
          operate his printing business and to pay certain personal                   
          expenses.                                                                   
               On February 1, 1999, and January 1, 2003, petitioner filed             
          Forms W-4, Employee’s Withholding Allowance Certificate, falsely            
          stating, under penalty of perjury, he was exempt from withholding           
          taxes.  On January 20, 2004, respondent advised petitioner that             
          respondent had received information that he might be involved               
          with American Rights Litigators (ARL), an abusive tax avoidance             
          scheme.  On February 4, 2004, petitioner mailed respondent a                
          letter in which he falsely denied involvement with ARL.  On May             
          11, 2004, respondent served a summons on petitioner requesting              
          that he appear on June 2, 2004, to answer certain questions and             
          provide records regarding his income taxes.  Petitioner did not             
          comply with the summons.  On November 30, 2004, the U.S. District           
          Court, Northern District of California ordered petitioner to                

               5On brief, respondent conceded the additional unreported               
          income for 2002.                                                            





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