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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.
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