- 6 - Petitioner continued to maintain similar arguments through investigation of his liability for subsequent years, during a criminal case brought against him, through trial of this proceeding in February 2004, and in his posttrial brief. The criminal case that was commenced against petitioner was dismissed in 2001 when the presiding judge indicated that the matter should be pursued civilly rather than criminally. In 1998, petitioner and his wife incorporated a business as Strategic Computer Solutions. The corporation had employees, including petitioner and his wife, and issued Forms W-2, Wage and Tax Statement, at the end of each year. Federal income taxes and Social Security taxes on the employees, including petitioner and his wife, were withheld, and the withheld taxes were paid to the IRS. Petitioner and his wife filed joint returns and reported their wages for 1998 and subsequent years. OPINION Petitioner has not raised any nonfrivolous arguments concerning the amount of deficiencies determined in the statutory notice. He has asserted various arguments concerning procedural matters and failures of the Government to prepare returns on his behalf and to assess promptly the amounts owing. He rejects the Court’s explanation that assessment cannot occur until the decision in this case is final. See sec. 6213(a). He acknowledged during his testimony that he did not consult withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011