Jerry D. Criner - Page 6

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          for ad valorem property taxes on the Claremore property for 1989,           
          1990, 1991, and 1992.  Petitioner also paid the 1993 ad valorem             
          property taxes on the Claremore property with a check drawn on              
          the account of “Cass Criner, a minor, Jerry Criner, custodian,              
          UTMA”.  On November 29, 2000, petitioner’s 18-year-old son,                 
          Candon Criner, purchased a cashier’s check in the amount of                 
          $1,233.86, payable to the Rogers County Treasurer.  At that time,           
          Candon Criner probably was not living at the Claremore property             
          and would not have had the money to buy the cashier’s check                 
          without petitioner or one of petitioner’s brothers or sisters               
          giving him the funds.                                                       
          Petitioner’s Tax Liabilities                                                
               Petitioner did not file Forms 1040, U.S. Individual Income             
          Tax Return, for 1990 through 1993. Petitioner signed a Form 870,            
          Waiver of Restrictions on Assessment and Collection of Deficiency           
          in Tax and Acceptance of Overassessment, on July 31, 1996,                  
          consenting to the assessment of deficiencies in income tax and              
          additions to tax under section 6651(a)(1) for 1990 through 1993.            
          Respondent assessed the deficiencies in income tax and the                  
          additions to tax under section 6651(a)(1) for 1990 through 1993             
          on September 9, 1996.                                                       
               On December 4, 2001, petitioner’s collection matter was                
          assigned to Revenue Officer Dale Baustert.  Mr. Baustert’s review           
          of the file revealed that collection actions had been initiated             






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