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FINDINGS OF FACT
None of the facts have been stipulated. The exhibits
received into evidence at trial are incorporated herein by this
reference. At the time he filed the petition, petitioner resided
in Clinton, Michigan.
Petitioner did not file Federal income tax returns for 1995
and 1996.
On April 24, 1998, respondent mailed petitioner separate
notices of deficiency for 1995 and 1996. For 1995, respondent
determined a deficiency of $155,195, an addition to tax pursuant
to section 6651(a)(1) of $36,924.50, and an addition to tax
pursuant to section 6654 of $7,963.40. For 1996, respondent
determined a deficiency of $8,263, an addition to tax pursuant to
section 6651(a)(1) of $2,065.75, and an addition to tax pursuant
to section 6654 of $439.79.
Petitioner timely received these notices of deficiency.
Petitioner voluntarily chose not to file a petition with the
Court with respect to 1995 and 1996.
On September 21, 1998, respondent assessed the deficiencies
and additions to tax for 1995 and 1996 determined in the notices
of deficiency.
In 1998, petitioner filed a power of attorney with
respondent authorizing Joseph John Brune III and Thomas W.
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