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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 in
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