Robert A. Fisher - Page 3

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                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts is incorporated herein by this                     
          reference.  Petitioner resided in Silver Spring, Maryland, at the           
          time he filed his petition.                                                 
               Petitioner did not file Federal income tax returns for the             
          taxable years 1987 through 1992.  When respondent's revenue agent           
          first contacted petitioner, petitioner refused the revenue                  
          agent's request to file the appropriate tax returns and refused             
          to provide any of his books and records or copies of bank                   
          statements.  The revenue agent obtained information reporting               
          documents (IRP) which had been filed with the Internal Revenue              
          Service and which reported miscellaneous income paid to                     
          petitioner by third parties.  Included in the IRP data were Forms           
          1099 which reported amounts petitioner received from the sale of            
          securities.  The revenue agent included the proceeds of each                
          security sale reported on the IRP data in petitioner's income.              
          Petitioner never provided information to respondent's revenue               
          agent regarding the cost basis of the sold securities.  However,            
          to the extent respondent's revenue agent was able to obtain                 
          information regarding petitioner's cost basis, gain from the sale           
          of the securities was reduced by the verifiable cost basis.                 
               Using the IRP information, the revenue agent identified                
          several bank accounts that were in petitioner's name or in the              





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