Wayne D. Bumgarner - Page 3

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            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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