- 7 - 'United States' in order to specify any of several possible definitions applicable to these terms." (4) In request 6, respondent asserted that petitioner did not receive any income from sources outside the United States during the years in issue. In response, petitioner stated that "respondent does not cite statute and its implementing regulation defining the terms 'income' or 'United States' used in the allegation." (5) In request 10, respondent asserted that petitioner reported on his tax returns for 1983 through 1985 that certain wages were excluded from gross income as income earned while physically present in a foreign country during the entire 12 months of the taxable year. In response, petitioner contended that the "Statements are presumptive of law and are not facts susceptible to admission or denial by petitioner." In addition, petitioner stated that "respondent does not define the term 'wages' or the term 'taxable years' used in reference to petitioner in this case" and that "respondent fails to identify any * * * authority for establishing California [as a] state under federal revenue jurisdiction." (6) In requests 15 through 17, respondent asserted that during 1984 through 1986, petitioner conducted a tax return preparation and tax counseling business and that petitioner received, but failed to report, fees in 1984, 1985, and 1986. Respondent listed the names of specific payors and the amountsPage: 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