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estimated tax payments for 1993, 1994, and 1995. No amounts were
withheld by Biddle for any of the years at issue from the com-
pensation that Biddle paid petitioner during those years.
Petitioner and his wife, Donna Leggett (Ms. Leggett), filed
joint Federal income tax returns, Forms 1040 (returns), for 1988,
1989, 1990, and 1991, in which they reported the following
adjusted gross income and tax liability:
Year Adjusted Gross Income Tax Liability
1988 $38,495 $4,144
1989 37,280 3,551
1990 33,685 2,816
1991 31,970 2,651
On March 4, 1994, petitioner submitted to the Service Forms
1040NR, U.S. Nonresident Alien Income Tax Return (Forms 1040NR),
for the years 1984 through 1992. Handwritten at the top of those
forms were the words "AMENDED RETURN". Most of the lines in
those forms were stricken out and other lines in those forms
contained the notation "N/A". The word "(DEFERRED)" appeared on
the line showing "Amount * * * REFUNDED TO YOU".
Around January 1994, respondent assessed frivolous return
penalties (civil penalties) against petitioner and Ms. Leggett
for filing frivolous Forms 1040NR. Thereafter, but prior to May
24, 1994, respondent commenced collection efforts against pe-
titioner and Ms. Leggett for those penalties. In response to
those collection efforts, petitioner wrote a letter to the
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