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In 1990, petitioner was employed by and received W-2 income from
Dana Transport totaling $753. In addition to the W-2 income
received during 1989 and 1990, petitioner worked for and received
income from Lighthouse Transport (Lighthouse) during both years.
Petitioner had no other source of income during these years.
During the years in issue, petitioner resided in Chicago,
Illinois, with his aunt to whom he paid rent in the amount of
approximately $200 per month. Petitioner gave money to his 17-
year-old daughter who was not living with him and also paid his
own living expenses, which included the cost of food, clothing,
recreation, gasoline, and car insurance. In addition, petitioner
paid lodging expenses for stays in motels between six and eight
times a month. Petitioner had no checking or savings accounts
during the years in issue.
In 1991, petitioner was employed by Dana Transport from
which he received somewhere between $30,000 and $40,000 in W-2
income during the taxable year.
On February 6, 1992, petitioner was involved in a traffic
accident resulting in a fire in his truck in which all of his
then-existing records were destroyed.
Respondent mailed a notice of deficiency to petitioner with
respect to 1989 and 1990 on June 28, 1995. Because petitioner
did not file income tax returns for these years, the notice of
deficiency was based upon substitute returns prepared by
respondent. In the notice of deficiency, respondent determined
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