- 6 - 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 initiatedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011