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FINDINGS OF FACT
Some facts were stipulated. The parties’ stipulation of
facts and the exhibits submitted therewith are incorporated
herein by this reference. We find the stipulated facts
accordingly. Petitioner resided in Omaha, Nebraska, when his
petition was filed.
Respondent’s records contained no information on
petitioner’s having filed a 1997 Federal income tax return.
Respondent prepared a substitute for return for that year. On
November 30, 2001, respondent issued to petitioner a notice of
deficiency on the basis of the substitute for return.
Petitioner received the following items of income during
1997:
Payor Amount Type
Integrated Business $82,500 Nonemployee
Strategies, Inc. compensation
ACI, Inc. 53,092 Wages
First Deposit 19 Interest
National Bank
First Bank, N.A. 47 Interest
First Bank, N.A. 50 Interest
Capital One, F.S.B. 14 Interest
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