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Background
A. Respondent’s Notice of Deficiency
Petitioner failed to file Federal income tax returns for the
taxable years 1995 and 1996. On February 19, 1998, respondent
prepared substitutes for return with respect to petitioner’s
taxable years 1995 and 1996. See sec. 6020(b).
On October 7, 1999, respondent issued a notice of deficiency
to petitioner. In the notice, respondent determined deficiencies
in and additions to petitioner’s Federal income taxes for 1995
and 1996 as follows:
Additions to Tax–Secs.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
1995 $31,046 $7,762 –- $1,683
1996 28,973 6,519 $4,346 1,542
Respondent determined that petitioner had attempted to assign all
or part of his income during 1995 and 1996 to several sham
trusts. Respondent allocated the unreported income to petitioner
and determined that such income was subject to self-employment
tax.
B. Petitioner’s Imperfect Petition
On or about December 3, 1999, petitioner and his wife,
Elaine Horejs, wrote a letter to the Court requesting a form for
filing a petition for redetermination. The Court filed
petitioner’s letter as an imperfect petition, assigned docket No.
18537-99, and directed petitioner to file an amended petition.
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Last modified: May 25, 2011