Michael Stein - Page 7

                                        - 7 -                                         
          institutions that withheld taxes from his interest and dividend             
          income.                                                                     
               As of July 26, 2001, petitioner had failed to file Federal             
          income tax returns for his tax years 1988 through 2000.4  There             
          is no record information or other evidence that petitioner has              
          filed returns for his 1992 through 1994 tax years.                          
               Petitioner “[dropped] everything” in 1988 when both his                
          elderly parents were ill with cancer.  Petitioner’s parents died            
          in 1990.  Since 1988, petitioner has had a “combination of health           
          problems (including * * * surgery)”.                                        
               Petitioner could not locate his 1987 return among his                  
          papers and other personal possessions that were packed in boxes             
          as a result of residential moves.  Petitioner eventually found a            
          copy of his 1987 return before trial but made no effort to have             
          it admitted into evidence.  Petitioner asserted his 1987 return             
          shows a capital loss carryover of $187,000 and an overpayment of            
          tax exceeding $12,000, and he had unspecified losses in                     
          subsequent years, including 1988 through 1993.                              
               During 1996, petitioner used his address at 25 West Elm                
          Street, Greenwich, Connecticut (the Elm Street address), to                 
          receive Forms 1099-B, Proceeds From Broker and Barter Exchange              



               4As of Jan. 6, 2003, petitioner had filed returns for his              
          1995 and 1996 tax years.                                                    






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