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Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Guttenberg, New Jersey.
From January 1, 1997, to April 1, 1999, petitioner was a
stockbroker at the American Stock Exchange in New York, New York.
During the years in issue, petitioner had various health problems
that required him to undergo surgery on an outpatient basis with
follow-up medical appointments about once a month. Also during
the years in issue, petitioner’s spouse, Barbara Appel, suffered
from severe health problems, and petitioner had to care for her
and manage the affairs of the household. Petitioner nevertheless
continued working at the American Stock Exchange with a few days
of absences due to his surgery and related follow-up medical
appointments.
Petitioner requested and received extensions to file his
Federal income tax returns for the 1997, 1998, and 1999 taxable
years. Taking into account such extensions, petitioner’s 1997
return was due October 15, 1998; his 1998 return was due October
15, 1999; and his 1999 return was due October 15, 2000. However,
petitioner did not file any Federal income tax returns by the
corresponding due dates.
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Last modified: May 25, 2011