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returns that he had purportedly filed for the years 1985, 1986,
1987, and 1988. The tax return for 1987 shows Schedule C income
of $42,671.50, rental income of $4,800, and total income of
$47,541.50. The tax return for 1988 shows Schedule C income of
$33,653, rental income of $5,000, and total income of $38,653.
Petitioner understated his taxable income for the years
1988, 1989, 1990, and 1991. Petitioner's failure to report such
taxable income resulted in underpayments of tax in each of those
years. Petitioner is liable for self-employment taxes on his
unreported income for each of those years. A part of
petitioner's underpayment of tax for each of the years 1988,
1989, 1990, and 1991 was due to fraud.
OPINION
Petitioner's Motion To Seal The Record
At the commencement of the trial in this case, petitioner
orally moved to seal the record. There being no objection from
respondent, the Court conditionally granted petitioner's motion.
In particular, by order dated May 22, 2000, the Court directed
petitioner to identify the particular evidence in the record that
should not be disclosed to the public. Petitioner failed to
comply with the Court's order.
Section 7458, which governs hearings before the Tax Court,
provides that such hearings shall be open to the public. In
addition, section 7461, provides in pertinent part:
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