- 5 - petitioner but should have been reported by Friedmann Management Corp. Id. at 511. Petitioner also prosecuted a case in this Court involving adjustments to his joint return for 1988 that was settled before trial pursuant to an agreement of the parties. Lastly, in 1996, he sued the United States to quash two Internal Revenue Service summonses, one of which demanded all documents and records regarding petitioner's assets, liabilities, and accounts for purposes of preparing a "collection information statement", and the other of which sought all books, records, documents, and receipts for income from all sources for purposes of preparing Federal income tax returns for 1991 through and including 1995 that had not been filed by petitioner. Friedmann v. United States, 79 AFTR 2d 97-895 (D.N.J. 1997). In that case, the court granted the Government's motion to dismiss petitioner's complaint. Id. Petitioner failed to timely file his individual Federal income tax returns for tax years 1989 through 1995. He filed delinquent returns for 1989 and 1990, the years at issue, as discussed below, but he had not yet filed his returns for tax years 1991 through 1995 at the time this case was tried.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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