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Petitioner refused to file delinquent returns because, in her own
words:
I could not truthfully and in good conscience sign a
return which swore that the information was correct
when I didn’t know it was. For a decade I’d not kept
records for tax purposes and the records I had
available probably were not complete and I would not
swear that they were.
On March 20, 1995, respondent issued the four notices of
deficiency that give rise to this case (one each for 1983 through
1985, 1986 through 1988, 1989 through 1991, and 1992 and 1993
(collectively, the notices of deficiency).
The Petition
Petitioner filed the petition on June 22, 1995. By the
petition, she assigns error to all of the determinations of
deficiencies in, and additions to, tax made by respondent in the
notices of deficiency, and she sets forth the following
disagreement with respondent:
I disagree with The “increase in Tax” & The
“Penalties” in each year, 1983 through 1993 for the
reason that more income than I earned was attributed to
me in each of those years & far less expense than I
incurred & am allowed to deduct was given in each of
those years.
Petitioner attached to the petition only the first page of each
of the notices of deficiency she received. Each of those pages
states, among other things (1) the amount of the deficiency in
tax and the penalty determined by respondent for each of the
years stated, (2) that an enclosed statement shows how respondent
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