- 3 -
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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