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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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