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FINDINGS OF FACT2
Petitioner resided in Ormond Beach, Florida, at the time the
petition in this case was filed.
During 1991-97, petitioner was in the insurance business.
He received the following income from commissions, interest,
dividends, and capital gain:
Year Commissions Interest Dividends Capital Gain
1991 $163,912 $438 -- --
1992 157,399 220 -- --
1993 230,581 173 $16 --
1994 215,378 177 20 --
1995 221,021 166 142 --
1996 261,240 131 1,424 $5,953
1997 342,891 118 2,157 9,551
Petitioner filed Federal income tax returns for all years
before 1991. He did not file returns for 1991-2001. Petitioner
did not make estimated tax payments for 1991-97, and no tax was
withheld with respect to any income petitioner earned during
those years.
In June 1998, the Internal Revenue Service began examining
petitioner’s records in order to determine petitioner’s income
tax liabilities for the years at issue. Petitioner refused to
meet with the examination officer. In addition, he refused to
2Petitioner refused to execute a stipulation of facts. In
his answering brief, petitioner did not object to any of
respondent’s requested findings of fact and did not offer any of
his own. The record amply supports respondent’s requested
findings. Consequently, respondent’s requested findings of fact
are incorporated herein.
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