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disposition of his alleged refunds for prior years.
3. Respondent’s Records
Respondent introduced a certification, under seal, attesting
to the fact that respondent’s master file does not include any
record of petitioner's having filed a Federal income tax return
for any of the years in issue. Respondent introduced a second
certification, under seal, attesting to the lack of record of
petitioner having filed a Federal income tax return for any of
the years 1988 through 1993.
In contrast, respondent introduced certificates, under seal,
reflecting transcripts of account for 1987 and 1994, years for
which the transcripts demonstrate that petitioner filed Federal
income tax returns. The transcript for 1987 indicates that
petitioner claimed an overpayment in the amount of $384.41, which
was refunded on May 16, 1988. The transcript for 1994 indicates
that on March 6, 1995, petitioner claimed an overpayment in the
amount of $2,720, which was offset against an outstanding
liability on that same date.
C. The Notices of Deficiency
In July 2000, respondent issued separate notices of
deficiency to petitioner determining deficiencies in and
additions to petitioner’s income taxes for 1995, 1996, and 1997.
For each of those years, respondent determined that petitioner
failed to file an income tax return and that petitioner received
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