- 8 - 1979, and $327,194 for 1980. Respondent also determined that petitioner had unreported taxable income of $238,640 for 1977. From 1991 through 1995, petitioner failed to provide to respondent any indication that these amounts were incorrect. OPINION Before discussing our conclusions with respect to fraud, we set forth the lengthy procedural history of this case. That history explains in part why we conclude that petitioner's representations are not credible and why we determine the deficiencies in issue against him by reason of his defaults. Procedural History In his petition filed June 10, 1991, petitioner alleged that all of respondent's determinations were in error. As the facts upon which he relied, he alleged: (A) At the present time, due to my incarceration at the Federal Correctional Institute Danbury, Route 37, Pembroke Station, Danbury, CT 06811, it is impossible for me to allege facts in support of my assignments of error as the necessary records and documents are not available to me. Upon my release, I will prepare an amended petition in order to comply with the Court's Rules. Petitioner designated New York, New York, as the place of trial for this case. Petitioner never sought leave to file an amended petition. In the answer, respondent alleged, in support of the determination that the underpayments of tax for the years inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011