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petitioner sold insurance and alarm systems. Petitioner does not
have a college degree. During these same years, petitioner also
performed bookkeeping and tax return preparation services for his
own clients.
On April 23, 1990, petitioner applied for an automobile
loan. On the loan application, petitioner indicated that his
annual income was $120,000.
During 1990 through 1993, petitioner did not maintain books
and records relating to any of his income-producing activities.
During 1975 through 1989, Mrs. Levine worked part-time in a
department store.
For years prior to 1988, petitioners timely filed their
Federal income tax returns.
For 1990 through 1993, petitioners did not timely file with
respondent their Federal income tax returns that were due, nor
did petitioners make any payments of estimated Federal income
taxes.
In January of 1994, petitioner was contacted by respondent’s
revenue agent about petitioners’ unfiled 1988 through 1992
Federal income tax returns.3
3 Respondent’s revenue agent who talked to petitioner in January
of 1994 testified herein that during that conversation petitioner
falsely stated that he already had filed his 1988 through 1992
Federal income tax returns. Petitioner contends that the
testimony of respondent’s revenue agent should be stricken and
excluded from the evidence herein.
(continued...)
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