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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 with
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Last modified: May 25, 2011