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stamped information was marked through in an attempt to make it
unreadable. On a date not specified in the record, an
unidentified person acting for respondent added a document
locator number to the upper right corner of the first page of
each photocopied return with original signature for the years in
issue.
Respondent mailed the notice of deficiency to petitioner for
tax years 1987-90 and 1992-97 on March 6, 2000.
D. Allnutt v. Commissioner
Petitioner previously filed a petition in this Court seeking
our review of the Commissioner’s determination of deficiencies in
petitioner’s income tax for 1981-86. Allnutt v. Commissioner,
T.C. Memo. 1991-6 (Allnutt I), affd. without published opinion
956 F.2d 1162 (4th Cir. 1992), cert. denied 506 U.S. 816 (1992).
In Allnutt I, we granted the Commissioner’s motion to dismiss the
case for failure to state a claim because petitioner made only
frivolous allegations. We also sustained the Commissioner’s
determination relating to deficiencies in petitioner’s income tax
for 1981-86 and decided that petitioner had the following amounts
of taxable income:
Year Amount
1981 $433,059
1982 409,575
1983 386,090
1984 342,223
1985 298,355
1986 1,913,176
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