- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011