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The deficiency in income tax is based on the disallowance of
deductions claimed by Rancho Residential on Schedule C, Profit or
Loss from Business. In this regard, respondent determined that
the deductions:
are disallowed because you failed to establish the
amount, if any, that was paid during the taxable year
for ordinary and necessary business expenses, and you
failed to establish the cost or other basis of the
property claimed to have been used in business.
B. Petition
The Court subsequently received and filed a petition for
redetermination challenging the notice of deficiency.4 The
petition was signed by Robert Hogue as Rancho Residential’s
purported “trustee”.
Paragraph 4 of the petition, which sets forth the bases on
which the notice of deficiency is challenged, alleges as follows:
(1) The Statutory Notice of Deficiency was issued to
petitioner claiming petitioner had unreported income.
Petitioner denies having any unreported income. (2)
Attached to the Notice of Deficiency, IRS Form 4549-A,
income tax examination changes, line 9 states, “Total
Corrected Tax Liability.” Petitioner denies having a
tax liability. (3) Respondent has failed to provide
the petitioners [sic] with the USC Title 26 taxing
statute that applies. (4) Respondent has failed to
provide the petitioners [sic] with certified assessment
information as per Internal Revenue Regulation
301.6203-1. (5) Respondent has failed to identify the
individual who will certify to the tax adjustments the
determination was based on. (6) Petitioner claims, the
Notice of Deficiency, the claimed tax liability, and
4 Rancho Residential’s principal place of business was in
California at the time that the petition was filed with the
Court.
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Last modified: May 25, 2011