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determinations were not based on any factual evidence. Here we
note that for 1991 and 1992, respondent's deficiency
determinations, as supplemented in respondent's motion to
dismiss, were based on admissions made by petitioner in Forms
1040X submitted by petitioner in July 1994. In other words,
petitioner has been charged with having no more income than the
amounts disclosed by petitioner on the Forms 1040X that he
himself submitted to respondent. Moreover, we note that
petitioner has repeatedly admitted that he failed to file income
tax returns for the years in issue, an admission that confirms
respondent's determination and that provides a basis for imposing
additions to tax under sections 6651(a)(1) and 6654(a).
Insofar as 1993 is concerned, we note that respondent's
deficiency determination is based on two Forms W-2 submitted to
respondent under petitioner's name and taxpayer identification
number. The Forms W-2 disclose the payment of wages by USX
Corporation in the amount of $24,411 and by Adwood Corporation in
the amount of $1,130.
We think it significant that petitioner has not denied that
he was employed by either USX Corporation or Adwood Corporation
in 1993. Indeed, petitioner has not even denied receiving the
amount of wages that respondent determined he received. If
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