- 5 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011