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Petitioner is a computer software engineer, specializing in
software development, testing, and quality assurance. From 1975
through 1980, petitioner was employed by various companies in the
computer field. He was employed as a test technician, field
representative, engineering technician, test department manager
and supervisor, and software engineer. He taught hardware and
software courses for employees and customers of two companies.
Petitioner filed Federal income tax returns as a single
individual for 1972 through 1975 and jointly with his wife for
1976, 1977, and 1979 through 1981. From 1987 through 1997,
petitioner failed to file Federal income tax returns.
Petitioner did not maintain bank accounts in his name during
the years in issue because he refused to provide his Social
Security number to banking institutions. From 1987 through 1997,
petitioner received compensation as an independent contractor in
the field of software development and quality assurance. The
checks that he received in payment for his services were cashed
at the payers’ banks or through bank accounts maintained by his
wife, his mother, or his sister-in-law.
Petitioner received gross receipts from his occupation as
follows:
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