Steven A. Monaco - Page 3

                                                - 3 -                                                   
                                             Background                                                 

                  Petitioner resided in Kihei, Hawaii, at the time he filed                             
            the petition.  During 1994, petitioner worked as a self-employed                            
            physical therapist and received nonemployee compensation in the                             
            amount of $41,201.23.  Also during 1994, petitioner sold a parcel                           
            of real property for $28,000.                                                               
                  Petitioner did not file a timely 1994 Federal income tax                              
            return and has made no payments regarding his 1994 income tax                               
            liability.  On October 16, 1995, petitioner sent a Form 1040NR,                             
            U.S. Nonresident Alien Income Tax Return, to respondent's service                           
            center in Philadelphia, Pennsylvania, which was received on                                 
            October 20, 1995.  Petitioner's Form 1040NR reported zeros on                               
            most lines, including those for income and tax.  Petitioner                                 
            altered the jurat and in the space for listing his occupation                               
            stated that he had no occupation within the United States.                                  
                  On April 18, 1997, respondent mailed a notice of deficiency                           
            to petitioner regarding his 1994 income tax liability.                                      
            Petitioner timely filed his petition with this Court on July 16,                            
            1997.  Respondent has made no assessment of tax regarding                                   
            petitioner's 1994 Federal income tax.                                                       
                  In July 1997, petitioner mailed a Form 1040, U.S. Individual                          
            Income Tax Return, for the taxable year 1994 to respondent's                                
            service center in Fresno, California.  Except for amounts                                   
            representing a claimed standard deduction and personal exemption,                           





Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011