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transactions for 1985-88. Petitioner never informed the revenue
agent of his belief that funds from his real estate transactions,
which were held in trust, were not subject to taxation.
Respondent reconstructed petitioner’s income and expenses for
1985, 1986, 1987, and 1988.
On September 5, 1990, respondent served a third-party
recordkeeper summons on Mr. Miles, which requested information
pertaining to petitioner’s income tax liabilities for the 1985-88
tax years. At the request of petitioner’s representative, Mr.
Miles did not provide the requested documents to the IRS. On
March 7, 1991, the Government filed a petition in the U.S.
District Court for the Middle District of Florida, Orlando
Division, to enforce the summons issued to Mr. Miles. On March
26, 1991, petitioner filed a motion to intervene in the
enforcement proceeding. On September 17, 1992, the Government
filed a notice to dismiss, and, on September 18, 1992, the court
canceled a show cause hearing and dismissed the summons
enforcement proceeding. On April 18, 1991, respondent served a
summons on petitioner. Petitioner failed to comply with the
summons, and the Government filed a petition to enforce the
summons in the U.S. District Court for the Middle District of
Florida, Orlando Division.
On June 12, 1997, an information was filed in the U.S.
District Court for the Middle District of Florida alleging that
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