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Failure To File
Petitioner did not file his income tax returns for the years
1997-2002 by their due dates.3 They all remained unfiled when an
agent of respondent contacted petitioner regarding petitioner’s
unfiled returns in October 2003. Petitioner ignored the agent
and did not submit any documents or information in response.
Respondent sent petitioner a deficiency notice on April 27, 2004.
Petitioner finally submitted returns for 1997 through 2002 to
respondent in July 2004, the same month he timely filed a
petition with this Court.
Petitioner’s Background
Petitioner has been a life insurance salesman since leaving
college. Petitioner’s life insurance business focused on
individual policies and very seldom involved group policies
during the years at issue. Petitioner is married, although he
and his wife have filed separate returns since their marriage.
Petitioner continued his life insurance business during the
years at issue. Petitioner experienced some success in his
business from 1997 through 2002. Petitioner’s annual reported
gross receipts from his life insurance business ranged from a low
of $104,368 in 1998 to a high of $387,456 in 2000. Petitioner’s
gross receipts for 1999 and 2000 were the highest of any of the 6
years 1997-2002.
3Petitioner’s accountants, acting under a limited power of
attorney, obtained extensions of time to file petitioner’s
returns for each year from 1997 through 2002. Each return was
therefore due October 15 of the following year.
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