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FINDINGS OF FACT2
The parties have stipulated certain facts which we
incorporate herein by this reference. When petitioner filed his
petition, he resided in Liberty Hill, Texas.
Petitioner’s 1992 Tax Return
On his 1992 Federal income tax return, petitioner reported
$3,681 of gross income and claimed a $294.59 refund. On this
return, petitioner listed his address as 7262 Madeira Drive, Fort
Worth, Texas 76112 (the Madeira Drive address), which was also
his parents’ address.
Respondent’s Examination of the 1992 Tax Return
By letter dated August 17, 1994, and addressed to the
Madeira Drive address, respondent notified petitioner that,
according to third-party information reports, petitioner had
received $10,744 of nonemployee compensation that was not
reported on his 1992 tax return. The letter requested petitioner
to provide information about this matter within 30 days.
2 Petitioner failed to file an opening or reply brief.
Consequently, the Court did not have available either
petitioner’s proposed findings of fact or any objections he might
have had to respondent’s proposed findings of fact. Although we
might deem petitioner to have conceded respondent’s proposed
findings of fact, see Rule 151(e)(3); Estate of Jung v.
Commissioner, 101 T.C. 412, 413 n.2 (1993), we instead base our
findings of fact on the record before us.
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