- 3 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011