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was able to, and did, prevent a Form W-2 (Wage and Tax Statement)
from being sent by that company to him, the Internal Revenue
Service, or the State of Arizona with respect to his wage income
for each of the years 1984 through 1988. Nor were any Forms 1099
filed in the name of petitioner for those years.
During 1985, petitioner established The Five Star Trust and
began to transfer certain of his assets into the name of that
trust.
Discussion
Petitioner bears the burden of proving that respondent's
determinations in the notices of the deficiencies and the addi-
tions to tax under section 6654 are in error. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). Respondent bears the
burden of proof on the fraud issue, and that burden is to be
carried by clear and convincing evidence. Rule 142(b); sec.
7454(a).
Throughout the course of this proceeding from its commence-
ment when petitioner timely filed a petition in this Court
through the brief that he filed after this case was submitted,
petitioner has persisted in advancing matters that are, inter
alia, frivolous, groundless, irrelevant, immaterial, and/or
nonsensical.
On the record before us, we find that petitioner has failed
to show error in respondent's determinations of the deficiencies
and the additions to tax under 6654. Consequently, we sustain
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