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Respondent’s motion points out that “petitioner’s sole
issue set forth in his Amended Petition is that he has
‘been the victim of an eleborate [sic] fraud’”, a theory
that, respondent asserts, “has no bearing on the tax
deficiencies set forth in the notice of deficiency for
tax years 2000 and 2001.” Respondent’s motion details
petitioner’s fraud theory, which involves petitioner’s
divorce and a Florida State court order under which
petitioner’s wages were garnished to pay child support
for a child who petitioner claims does not exist.
Respondent’s motion also details the factual basis for
finding that petitioner had earned the income underlying
the taxes and additions to tax determined in the subject
notices of deficiency. Respondent’s motion states that
during the years in issue petitioner received income from
three sources: (1) Wages from the City of Austin, Texas,
for work as a crossing guard; (2) distributions of
retirement pay from the Defense Finance and Accounting
Service attributable to his retirement from the U.S. Air
Force; and (3) a distribution from the Prudential Insurance
Co. of America (herein Prudential) attributable to the
cancellation of a life insurance contract for failure to
pay a policy loan. Petitioner’s income from these sources
is summarized as follows:
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