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erroneous. He argues merely that he has been denied due process
because he was not permitted at the administrative level to argue
his theories that his income is not taxable. By reason of his
failure to present evidence, all issues other than the additions
to tax for fraud under section 6653(b) and the penalties for
fraudulent failure to file returns under section 6651(f), as to
which respondent has the burden of proof, are decided against
petitioner. See Rules 123, 142(a), 149(b).
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided at the Federal
Prison Camp at Duluth, Minnesota.
Prior to and during the years in issue, petitioner operated
a hospital supply business known as Allied Medical Associates
(Allied). The business was operated out of petitioner’s
residence. For the years in issue, Allied received income from
sales in the following amounts:
Year Amount Received
1987 $385,291.83
1988 472,287.70
1989 541,307.68
1990 557,189.48
1991 469,658.69
1992 464,070.32
1993 442,100.83
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