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Respondent also determined that petitioner was liable for self-
employment tax and for additions to tax for failure to file tax
returns and for failure to pay estimated tax.
In the petition filed October 27, 1997, petitioner’s
disagreement with the adjustments was stated as follows:
I received no taxable income during the tax years
of 1982 and 1983 from Santa Ana Immigration Center or
any other source; therefore there is no responsibility
for paying taxes in this matter because no income was
personally collected, earned or received.
At no time did petitioner amend the petition to allege that he
filed returns or to state any other special matter.
The case was first set for trial on June 7, 1999, by notice
served December 31, 1998. On May 26, 1999, petitioner filed a
petition with the U.S. Bankruptcy Court for the Southern District
of California under 11 U.S.C. chapter 7. On June 9, 1999,
petitioner filed an adversary proceeding in the bankruptcy court
against the United States of America. The gist of petitioner’s
complaint was that his books and records used by the IRS in
making the determinations at issue in this case were wrongfully
seized by the INS in 1988. Pursuant to stipulation, on August 4,
1999, petitioner’s action against the United States of America
was dismissed.
On June 16, 1999, petitioner also filed an adversary
proceeding in the bankruptcy court against a former employee of
the INS and against Nanni. The gist of the complaint in this
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