David M. Leggett - Page 7

                                        - 7 -                                         
          to answer any of their questions, they informed him that the                
          meeting was concluded and asked him and the individuals who                 
          accompanied him to leave.  After the September 1995 meeting,                
          petitioner sent a letter to the revenue agent's supervisor                  
          complaining that he had been denied due process.  Petitioner did            
          not provide to the Service at the September 1995 meeting, or at             
          any other time, any documents or information from which his tax             
          liability could be determined for the years for which he did not            
          file returns.                                                               
               The Service's audit of petitioner continued from August 1995           
          through October 1996.  That audit took significantly longer than            
          that type of audit should have taken because petitioner refused             
          to cooperate with the revenue agent or any other representatives            
          of the Service.  As a result of petitioner's refusal to cooperate           
          with the Service, the Service had to conduct an extensive in-               
          vestigation in order to determine petitioner's income for each of           
          the years at issue and other information relevant to determining            
          his tax liability for each such year.                                       
               On February 19, 1988, petitioner acquired his residence                
          located at 5136 Neponset Avenue, Orlando, Florida (Neponset                 
          property) for $98,000.  In acquiring that property, petitioner              
          obtained on February 19, 1988, a mortgage loan from the Cal-                
          ifornia Federal Savings and Loan Association in the amount of               
          $78,400.  During 1992, petitioner paid principal and interest               
          totaling $24,983 on the mortgage loan on the Neponset property,             

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011