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Unless otherwise stated, section references are to the
Internal Revenue Code.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in High Springs, Florida, when he filed the
petition. He was married in 1995-96. His wife did not earn any
income in those years. Petitioner was a self-employed truck
driver in 1995-96. He received self-employment income as
follows:
Payor 1995 1996
McCollister’s Moving & Storage, Inc. $161,115 $34,295
North American Van Lines, Inc. 749 ---
Suddath Van Lines, Inc. --- 98,500
Total 161,864 132,795
B. Petitioner’s Income Tax Returns
Petitioner filed his Federal income tax return for 1994 on
December 27, 1996. Petitioner did not timely file a Federal
income tax return for 1995 or 1996.
North American Van Lines and Suddath Van Lines filed with
respondent Forms 1099-MISC, Miscellaneous Income, showing that
they had paid petitioner $749.50 in 1995 and $98,500.65 in 1996.
Respondent audited petitioner’s 1995 and 1996 tax returns
and, on May 18, 1998, sent a 30-day letter to petitioner by
certified mail. Petitioner received this letter.
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