Duane S. Ashley - Page 2




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          that respondent may.                                                        
                                  FINDINGS OF FACT                                    
               Virtually all of the facts have been deemed established                
          pursuant to the Court’s Order under Rule 91(f)1 dated September             
          5, 2002.                                                                    
               Petitioner resided in Beaufort, South Carolina, on the date            
          he filed the petition in this case.                                         
               Petitioner worked for the U.S. Government (Government) from            
          1973 until January or February 1987, when the Government dis-               
          charged him.  At the time of his discharge, petitioner was                  
          working for the Parris Island Marine Corps Recruit Depot.  After            
          his discharge in early 1987, petitioner made various claims                 
          against the Government, which were not resolved to his satisfac-            
          tion.  In an effort to have such claims resolved by a Federal               
          court, petitioner decided not to, and did not, file a Federal               
          income tax return (return) for taxable year 1989 or any taxable             
          year thereafter.                                                            
               On August 12, October 7, November 18, and December 30, 1991,           
          respondent sent petitioner delinquency notices with respect to              
          his taxable year 1989.                                                      
               On April 28, 1992, respondent sent by certified mail to                
          petitioner’s last known address, i.e., Star Route 6, Box 295�A,             


               1All Rule references are to the Tax Court Rules of Practice            
          and Procedure.  All section references are to the Internal                  
          Revenue Code in effect at all relevant times.                               




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