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resided in Chicago, Illinois.
Throughout the years at issue until the time of the trial in
this case, petitioner, who received a master’s degree in music
from Northwestern University, has worked as a sales manager and
as a singer/composer.
During World War II, when petitioner’s mother was 13 years
old, and when petitioner’s father was 17 years old, the U.S.
Government confined each of them and their respective families in
certain Government facilities because of their Japanese ancestry.
Petitioner’s parents made petitioner aware of their respective
experiences in those facilities.
The last tax return (return) filed by petitioner was for his
taxable year 1991. Petitioner did not file a return for any of
the taxable years at issue, although he received timely one or
more Forms W-2, Wage and Tax Statement, and one or more Forms
1099-NEC, Non-Employee Compensation, for each of those years.
No physician or psychologist has made a determination that
petitioner suffered from a mental illness or condition that
prevented him from complying with the tax laws for the years at
issue.
Respondent sent to petitioner a notice of deficiency (no-
tice) for petitioner’s taxable years 1994 and 1995, a separate
notice for petitioner’s taxable years 1996, 1997, and 1998, and a
separate notice for petitioner’s taxable years 1999 and 2000. In
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