- 3 - years in question. For the reasons that follow, we hold that they should. All section references, unless otherwise specified, are to sections of the Internal Revenue Code in effect for the years in issue. This case was submitted on a full stipulation of facts, and the facts are so found. This reference incorporates herein the stipulation of facts and attached exhibits. Petitioner resided in Eugene, Oregon, at the time he filed his petition. Background Petitioner failed to file Federal income tax returns for the taxable years 1987, 1992, and 1993, and untimely filed a Form 1040, U.S. Individual Income Tax Return, for the taxable year 1991 on August 19, 1994. Consequently, substitute returns were prepared by respondent in connection with her examination of petitioner's tax liability for those years. Respondent premised the substitute returns on information provided by payers of the gross income and third party recordkeepers. During 1987, petitioner was employed by the City of Eugene and was paid $25,584. The City of Eugene withheld Federal income tax of $2,103 from petitioner's wages during 1987. Petitioner also earned $48 of interest income in 1987 from one or more unspecified sources. During 1991, petitioner worked for Emerald Valley Development (Emerald Valley), and was paid $3,000. EmeraldPage: Previous 1 2 3 4 5 6 7 8 9 Next
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