Thomas G. Brenner - Page 3

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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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