- 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. Emerald
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