- 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011