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received $160,321.90 in long-term capital gains, incurred
$1,747.11 in short-term capital losses, and received $1,744.71 in
ordinary dividends. Petitioner incurred and paid $12,575.47 in
investment interest expenses in 1999.
Petitioner’s 1999 income tax return was due, pursuant to an
extension, on August 15, 2000. Petitioner did not file his 1999
income tax return by August 15, 2000, or at any time prior to
June 15, 2003, as set forth below. The notice of deficiency in
this case was sent on April 9, 2002. The notice was based on
total income reported to the Internal Revenue Service (IRS) by
financial institutions with which petitioner did business. On
July 8, 2002, petitioner filed his petition, in which he claimed
that there was no tax due for 1999.
On September 2, 2002, respondent’s Appeals officer wrote to
petitioner asking petitioner to set up a conference for possible
settlement of this case. Petitioner did not respond to the
letter. On January 7, 2003, the Appeals officer again wrote to
petitioner asking that petitioner call Appeals or send the
Appeals officer information that supported petitioner’s case.
On January 14, 2003, this case was set for trial at the
trial session of the Court in New York, New York, beginning on
June 16, 2003. Attached to the notice of trial was the Court’s
Standing Pre-Trial Order that provided, among other things:
You are expected to begin discussions as soon as
practicable for purposes of settlement and/or
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