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references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Petitioner resided in Chicago, Illinois, when he petitioned
the Court. Petitioner did not file Federal income tax returns for
any of the taxable years 1986 through 1995. During these years
petitioner earned the bulk of his income by working as a computer
programmer/consultant for various companies and hospitals.
Petitioner also had small amounts of interest and capital gain
income in 1987.
Petitioner made no estimated tax payments to the Internal
Revenue Service with respect to any of the years in issue.
However, petitioner had the following amounts withheld from his
wages:
Year Withholding
1987 $1,986
1993 1,295
1994 5,283
1995 5,413
Petitioner is homosexual. In 1989, petitioner began a
relationship with another man whom petitioner describes as his
roommate and partner. From 1989 through 1995 petitioner and his
partner resided together and shared assets and income.
Petitioner was not married (to his partner or anyone else) as of
December 31 for any of the taxable years 1986 through 1995. In
the notice of deficiency mailed to petitioner, respondent
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