David M. Priestly, Jr. - Page 2

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          1988 Federal income tax and related liabilities of $17,801.2  In            
          response to that notice, petitioner timely petitioned this Court            
          for review of respondent’s determination to proceed with                    
          collection.  Our jurisdiction in this case is established by                
          section 6330(d).                                                            
               Some of the facts in this case have been stipulated and are            
          so found.  At the time the petition was filed, petitioner was a             
          resident of California.                                                     
               Petitioner’s untimely 1988 Federal income tax return was               
          filed on January 13, 1991.  On the return, petitioner’s address             
          is shown as 24143 Palomino Dr., Diamond Bar, California (the                
          Diamond Bar address).  Petitioner reported wages of $42,926 from            
          his employment as an engineer with General Dynamics Corp.  There            
          were no Federal income tax withholdings on petitioner’s wages               
          from General Dynamics Corp.  There are two Schedules C, Profit or           
          Loss From Business, included with petitioner’s return.  One is              
          for a business described as a “tax preparation/consulting”                  
          service; the other is for a business described as a “property               
          management” service.  Approximately $5,100 of gross income is               
          reported and approximately $21,000 of expenses are deducted on              

               2 Other liabilities were referenced in the notice, but this            
          Court has no jurisdiction over respondent’s determination with              
          respect to those liabilities.  See the Jan. 10, 2000, Order                 
          granting respondent’s Motion to Dismiss for Lack of Jurisdiction            
          and to Strike as to the 1990 Tax Return Preparer Penalty.                   

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