Vincent Michael Coomes - Page 3

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          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulation of            
          facts and the attached exhibits are incorporated herein by this             
          reference.  Petitioner resided in Cincinnati, Ohio, at the time             
          his petition was filed.                                                     
               Petitioner operated Imperial Communications, Inc.                      
          (Imperial), as a sole proprietorship during the years at issue.             
          Imperial did not have any employees.  The services petitioner               
          provides through Imperial include installing and maintaining                
          telephone systems.  Petitioner was directly compensated by                  
          Imperial’s clientele for the services provided and goods sold for           
          1993, 1994, 1995, 1996, 1997, and 1998.  Moreover, petitioner               
          received interest income in 1997 and 1998 and dividend income in            
          1998.                                                                       
               Petitioner failed to file Federal income tax returns for               
          1993, 1994, 1995, 1996, 1997, and 1998.  Petitioner also failed             
          to make estimated tax payments during these years in connection             
          with his income from Imperial’s business and from other sources.2           
          Accordingly, on March 11, 2003, respondent issued a notice of               
          deficiency to petitioner which determined the amount of tax owed            


               2Other sources includes the interest and dividends                     
          petitioner received.                                                        





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