-3-
herein by this reference. Petitioner resided in Phoenix,
Arizona, when his petition was filed.
Petitioner has not filed a 1994, 1995, or 1996 Federal
income tax return. On February 14, 2001, respondent prepared
substitutes for returns on the basis of information received from
third parties. The information reported that the third parties
had paid to petitioner the following wages during the subject
years:
Payor Year Amount
Rescue Industries, Inc. 1994 $15,287
1995 18,855.85
1996 23,514
La Quinta Inns, Inc. 1995 115
Courier Management Services, Inc. 1995 5,501
1996 187
Respondent determined petitioner’s tax liability as to those
payments by considering his filing status to be “Single”.
Petitioner failed to cooperate with respondent in the audit
of his tax liability for the subject years, and petitioner has
failed to cooperate with respondent during this proceeding. At
trial, petitioner did not answer any substantive questions as to
his tax liability. Relying upon the Fifth Amendment, petitioner
claimed that he was refusing to answer those questions because
his answers might incriminate him.
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