- 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