- 4 -
money paid to the trust for petitioner’s services is taxable
income to petitioner.
During 1998, the IRS commenced an examination of
petitioner’s returns for the years in issue. The revenue agent
reviewed petitioner’s returns, Arivada’s returns, HOMC’s returns,
correspondence from petitioner to various other employees of the
IRS, documents at the Arizona Corporation Commission and the
recorder’s office, records for bank accounts, and checks signed
by petitioner. The revenue agent issued summonses for bank
account records and analyzed them, concluding that the deposits
shown were similar to the amounts reported on the HOMC returns.
Petitioner did not provide any documents during the examination
and did not meet with the revenue agent who had audited his
account until December 6, 2001, less than 2 months before trial
of this case.
Petitioner filed a chapter 13 bankruptcy petition with the
U.S. Bankruptcy Court for the District of Arizona on October 19,
1998. On October 21, 1998, the bankruptcy court lifted the stay
so that litigation in petitioner’s case for 1993 and 1994 could
proceed. The notice of deficiency in this case was sent to
petitioner on July 3, 2000. Petitioner’s chapter 13 bankruptcy
case was dismissed on December 26, 2000.
Arivada filed a bankruptcy petition on or about October 22,
1998. Arivada’s bankruptcy case was dismissed on November 23,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011