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A hearing on the cross-motions to dismiss Universal was held
on June 19, 20, and 27, 2000. Mr. Chisum claimed to represent
Universal at this hearing; he also testified briefly on its
behalf. At the end of this hearing, the Court took the motions
under advisement, pending resolution of the case at hand.
Although petitioner was pro se, the Court allowed Mr.
Chisum, who does not claim to be a member of the bar of any
court, to sit beside petitioner at trial. It appears that Mr.
Chisum has been advising petitioner on the conduct of his case.
Petitioner testified neither at the Universal hearing nor in
the case at hand.
Background
The record consists primarily of two sets of stipulations
with exhibits, and a very limited amount of testimony. The
stipulations are incorporated herein by this reference.
Petitioner resided in Lake Forest, California, when the
petition was filed. Petitioner neither filed an income tax
return for 1993 nor paid any estimated tax for that year.
Respondent sent the statutory notice to petitioner on
November 18, 1998. The notice stated that $104,786 of unreported
business (Schedule C, Profit or Loss From Business) gross
receipts were includable in petitioner’s income. It contained no
further explanation of this item. The computation of tax
included in the notice did not allow petitioner any deductions
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