- 4 - than result in respondent's considering the matter, in the words of respondent's examining revenue agent, as "basically a protestor case". Set against the background of this correspondence, the years here in dispute were assigned to a revenue agent for examination sometime in the fall of 1993. The revenue agent attempted unsuccessfully to contact petitioner at petitioner's place of employment1 on December 2, 1993. The examination was closed on January 10, 1994, and the notice of deficiency upon which this case is based was issued on March 23, 1994. Because petitioner did not file Federal income tax returns for the years in issue, or keep any records reflecting the amount of income he earned and expenses he incurred during those years, and because there was little meaningful communication between petitioner and respondent during the examination stage, respondent reconstructed petitioner's income for each year relying in part upon information received from third-parties, and in part upon information published by the United States Bureau of Labor Statistics (BLS). The reconstruction of petitioner's income for each year as set forth in the notice of deficiency is summarized in the following table: 1989 1990 1991 1992 1The words "employment", "employer", etc. are used for convenience throughout this opinion. The use of such words is not meant to imply the existence of an employer-employee relationship.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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