T.C. Memo. 2001-4
UNITED STATES TAX COURT
JOSEPH ALAN PIOLE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19094-96. Filed January 9, 2001.
Joseph Alan Piole, pro se.
John M. Zoscak, Jr. and Donna P. Leone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Chief Judge: Respondent determined deficiencies in
and an addition to tax for fraud and fraud penalties in respect
of petitioner’s tax liabilities for 1988, 1989, 1990, and 1991.
Because petitioner failed to maintain adequate tax records during
the years in issue, respondent relied upon the net worth (plus
expenditures) method to reconstruct petitioner’s taxable income.
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