-10-
overcharged us for materials and supplies. * * *
On February 3, 2003, State Auto commenced litigation in the
Maryland Circuit Court against petitioner and Mona Builders
(insurance litigation) in which it sought a declaratory judgment
that petitioner’s insurance claim was not covered by the insur-
ance policies that State Auto had issued to Mona Builders. At a
time not disclosed by the record after February 3, 2003, peti-
tioner and Ms. Davis filed a second amended counterclaim2 (insur-
ance litigation counterclaim) in the insurance litigation in
which they alleged, inter alia, that State Auto intentionally and
negligently misrepresented the terms of certain insurance poli-
cies that State Auto had issued to Mona Builders with respect to
the construction of the custom house. Petitioner and Ms. Davis
alleged in the insurance litigation counterclaim:
33. After taking occupancy of the residence [custom
house] in late August 2001, Davis [petitioner and
Ms. Davis] discovered numerous items of defective
or deficient work performed by MBD [Mona Builders]
that resulted in damages throughout the residence
to other parts of the residence. * * *
Petitioner did not file a tax return (return) for taxable
year 2000. Nor did he file a return for any of the taxable years
1995, 1996, 1997, 1998, and 1999.3 On March 20, 2003, respondent
2The record does not disclose any information about any
counterclaim that petitioner and Ms. Davis filed in the insurance
litigation before they filed the second amended counterclaim.
3Ms. Davis did not file a return for any of the taxable
(continued...)
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