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another person but was signed by petitioner. Petitioner did not
meet with Walden or produce requested records or documents.
On October 21, 1993, respondent issued a statutory notice of
deficiency to petitioner, determining deficiencies in income tax
for the 1986, 1988, 1989, 1990, and 1991 tax years and related
additions to tax. On the same date, respondent also issued a
statutory notice of deficiency to both Richard Nelon and Brenda
Nelon for the taxable year 1987, determining a deficiency in
income tax and related additions to tax.
At trial, petitioner acknowledged that he did not file
income tax returns for 1986 through 1991 and that he followed the
advice of Melton and the protester group that he did not have to
pay income taxes. After trial, the parties filed a stipulation
of settled issues. Among the issues settled, respondent conceded
that there was no deficiency in income tax due from, nor
overpayment due to, petitioner Brenda Nelon for the taxable year
1987. The parties also stipulated that petitioner was entitled
to deductions in connection with his logging business, as
follows:
Year Amount
1986 $127,038
1987 189,342
1988 188,927
1989 218,969
1990 194,088
1991 210,687
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