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Petitioner received compensation in the amounts and years at
issue:
Year Amount Payer
1986 $24,026 Bristol Industries, Inc.
1986 142,338 Gilkey Lumber Co.
1987 249,006 Gilkey Lumber Co.
1988 241,859 Gilkey Lumber Co.
1989 293,790 Gilkey Lumber Co.
1990 254,340 Gilkey Lumber Co.
1991 295,872 Gilkey Lumber Co.
The payers supplied Forms 1099 to respondent and petitioner
reflecting the above-listed payments. During the aforementioned
years, petitioner did not make any estimated payments of income
tax. Petitioner also did not file any income tax returns for the
years at issue. Petitioner maintained some records of his
expenses for his logging business in the form of receipts, which
he could not locate for purposes of trial.
Sometime in 1985, petitioner hired Larry R. Melton (Melton)
to paint his residence. Melton, who was not a qualified tax
adviser, was involved in a tax protester group. The primary
precept of members of the protester group was that they were not
subject to Federal income taxes. Consonant with that belief,
Melton advised that petitioner was not required to pay taxes to
the U.S. Government. Petitioner accepted Melton's advice, and he
joined the protester group, attended meetings, and paid dues
during 1987 and 1988. Beginning with his 1986 taxable year,
petitioner did not file a Federal income tax return in accord
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