- 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.
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