- 8 - they paid to petitioner. In response, petitioner stated that respondent failed to identify "by statute and regulation any activity for which petitioner would receive income from 'fees', or a statute and regulation identifying any amount in question as a 'fee'." (7) In requests 34 through 39, respondent attached copies of canceled checks and asserted that petitioner received these checks from clients of his tax return preparation and tax counseling business in exchange for services rendered. In requests 40 and 41, respondent attached a copy of a receipt given by petitioner to John Morales and asserted that the receipt was given by petitioner in exchange for payment by Mr. Morales for petitioner's income tax services. Petitioner's response to each of these requests was essentially the same: "petitioner objects to respondent's exhibit * * * as inconclusive of income, and respondent fails to identify as income under any statute and regulation, and is not identified as any income item by tax class or other identification." (8) In request 18, respondent asserted that, when interviewed by Internal Revenue Service (IRS) special agents concerning his income tax liabilities for the years in issue, petitioner told the agents that he was not in business, and did not own any interest in a business. In response, petitioner stated that he lacked "knowledge of any 'effectively connectedPage: 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