Richard P. Kringen - Page 5




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          wife had total projected monthly income of $4,354 and total                 
          projected monthly expenses of $4,200.  Petitioner signed the                
          statement of his projected monthly income and expenses under                
          penalties of perjury.                                                       
               Petitioner did not file a Federal income tax return for any            
          year in issue.  Except for $287 of Federal income tax withheld              
          from the compensation he received as an employee of Renaissance             
          in 1998, there were no Federal income tax withholdings or                   
          estimated Federal income tax payments made by petitioner during             
          any of the years in issue.                                                  
               Relying upon various indirect methods of determining income            
          that take into account information received from third parties              
          and the schedule of income and expenses filed in the bankruptcy             
          proceeding, respondent, in the notice of deficiency, computed               
          petitioner’s gross income for each year in issue as follows:                

                              Year            Income                                  
                              1990           $18,648                                  
                              1993           36,168                                   
                              1994           21,924                                   
                              1995           22,680                                   
                              1996           23,688                                   
                              1997           24,444                                   
                              1998           18,700                                   
          With the exception of the compensation that petitioner received             
          from Renaissance in 1998, respondent determined that all other              
          items of gross income for each year in issue constitute net                 







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