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incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in Dana Point,
California.
From 1984 through 1999, petitioner operated a sole
proprietorship under the name of Dana Point Bicycle Sport
(Bicycle Sport). Bicycle Sport was an independent bicycle retail
store engaged primarily in the business of selling new bicycles
and bicycle-related products to consumers and of repairing
bicycles.
Petitioner failed to timely file Federal income tax returns
or to pay any estimated taxes for the years at issue. As a
result, a revenue agent with the Internal Revenue Service,
Darrell Cavender, contacted petitioner in 1994 in an attempt to
secure the delinquent returns. When petitioner failed to submit
the requested returns, notices of deficiency based on records
obtained from third parties were issued to petitioner for the
subject years on April 29, 1996.
Thereafter, on October 26, 1998, petitioner filed tax
returns for all 6 years. Through the information provided on
such returns and additional financial materials obtained,
respondent concluded that the amounts for which petitioner was
determined to be liable should be reduced. At initial hearings
in this case on March 20 and 27, 2000, respondent communicated to
the Court the following revised amounts in dispute:
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