- 6 -
filed signed Federal income tax returns for the 1992 through 1994
tax years, but he was working with respondent’s revenue officer
to submit information to complete those returns. The Court
denied petitioner’s request for another extension of time to file
his brief and notified petitioner that the Court would decide the
case on the record and arguments previously submitted.
Factual Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Petitioner testified that “for purposes of the trial” and
when he filed the petition in this case, he resided at One
Strawberry Hill Court, Unit 11-C, Stamford, Connecticut (the
Strawberry Hill address). Petitioner testified he is a resident
of Nevada for State income tax purposes.
Petitioner testified he is a self-employed engineer who
travels up to 3 months at a time more than once a year. In Form
433-A, Collection Information Statement for Individuals, filed
with the Internal Revenue Service (IRS) on November 11, 1998,
petitioner said he was a “volunteer” and “not employed.”
Petitioner does not receive wages or salary from which tax
is withheld. During the tax years at issue, petitioner paid
estimated taxes, and petitioner held accounts with financial
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011