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Respondent concedes that if we exclude the documents, petitioner
is not liable for income tax deficiencies or additions to tax for
the years in issue. We hold the search was proper, the documents
will not be excluded, and petitioner is liable for tax
deficiencies and additions to tax in the agreed-upon amounts.
Background
Some of the facts have been stipulated and are so found.
The stipulated facts and the exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Acme, Washington, when he petitioned the Court.
Whatcom County sheriff's deputies entered and searched
petitioner's house on two separate occasions. The documents
petitioner seeks to exclude were seized in the course of the
second search, but the origins of the dispute trace back to the
first search.
2(...continued)
Revenue Code in effect for the years in issue. The parties have
since agreed that in the event the instant motion is denied,
petitioner will be liable for tax deficiencies and additions to
tax in the following amounts:
Additions to Tax
Sec. Sec.
Year Deficiency 6651 6654
1991 $11,108 $2,277 $638
1992 7,475 1,869 326
1993 727 182 32
1994 4,628 1,157 239
1995 3,639 910 199
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