- 5 -
whether petitioner had received income from criminal activity and
whether the amount of that income reached the threshold for the
filing of a Colorado income tax return. The State of Colorado
provided respondent with records that, in the State’s judgment,
reflected income to petitioner.
Respondent asked petitioner, who was then incarcerated, for
records of his business activities, and petitioner was unable to
produce any records other than those respondent received from the
State of Colorado. Petitioner advised that his records had been
discarded while he was incarcerated. Respondent did not allow
any deductions in connection with respondent’s determination of
petitioner’s business activity.
Petitioner failed to file Federal income tax returns for
1992 and 1993 as of the time respondent began the audit of
petitioner’s income activities. Petitioner did not provide
records of income or expenses to respondent in connection with
the examination of his 1992 and 1993 tax years. In the notice of
deficiency, respondent allowed petitioner standard deductions of
$3,600 and $3,700 for 1992 and 1993, respectively.
OPINION
During 1992 and 1993, petitioner was engaged in illicit
property transactions. The transactions generally involved real
property of corporations, unrelated in any way to petitioner,
that were delinquent in their obligations to the State of
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011