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Petitioner also owned and operated a pest control business
that served a 50-mile area in and around Broome County.
Petitioner operated this pest control business from his home and
an office located at the 99-101 Robinson Street, Binghamton,
property. Petitioner reported no income or expense from this
business. In the absence of any proof of income or of expense,
we leave this matter where the parties left it.
The Broome County Department of Social Services (Social
Services) reported on a Form 1099-MISC that it paid $26,618.70 to
petitioner in 1991. This amount represented rental payments for
clients of Social Services who occupied apartments in
petitioner's properties. According to documents from Social
Services, petitioner received payments in 1991 from Social
Services with respect to the following properties:
53 Mary Street, Binghamton, New York
99-101 Robinson Street, Binghamton, New York
18 Pleasant Avenue, Binghamton, New York
RD 2, Box 133 and Box 134, Conklin, New York
The Form 1099-MISC from Social Services was issued in
petitioner's name only. Neither petitioner, nor his wife,
reported this income on a 1991 tax return. Petitioner conceded
that he failed to file Federal income tax returns since 1984.
Respondent determined petitioner's tax liability based on
the $26,618.70 reported on the Form 1099-MISC from Social
Services, as well as on $5 of unreported interest income from
Marine Midland Bank. Respondent computed the deficiency with the
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