- 5 - At the hearing on respondent's motion, petitioner admitted that during 1991 he received payments in the following amounts from the persons indicated in return for labor he performed: Payor Amount Paid Milton Sharp $7,795.00 Transwestern 894.73 Codega & Fricke 3,479.00 MHM, Inc. 15,790.29 Redco 15,444.03 43,403.05 Petitioner also admitted at that hearing that he did not file a Federal income tax return for 1991. Petitioner bears the burden of proving that respondent's determinations in the notice are erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Respondent's concession of an error in the notice relating to the incorrect Form 1099 issued by Codega & Fricke in the amount of $6,791.10 does not shift that burden to respondent. Petitioner refused to enter into a stipulation of facts or to present any evidence at trial. Except for the error alleged in petitioner's amended petition relating to the incorrect Form 1099 issued to petitioner by Codega & Frick, the arguments he advanced in his amended petition are tax protester type arguments that have been repeatedly rejected by this Court and other courts. We so found in the Order dated January 12, 1995, that we issued with respect to respondent's motion. Nonetheless, inPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011