Steven W. Pond - Page 3

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               On April 8, 2003, respondent issued petitioner separate                
          notices of deficiency relating to 1995 through 1997, 1998 through           
          2000, and 2001.  In the notices, respondent determined that                 
          petitioner:  (1) Failed to report income relating to 1995 through           
          2001, (2) was liable for section 6651(f) additions to tax for               
          fraudulent failure to file returns relating to 1995 through 2001,           
          (3) was liable in the alternative for section 6651(a)(1)                    
          additions to tax for failure to file returns relating to 1995               
          through 2001, and (4) was liable for section 6654(a) additions to           
          tax for failure to pay estimated income taxes relating to 1996              
          through 2001.  On July 8, 2003, petitioner filed his petition,              
          and on August 28, 2003, respondent filed his answer.                        
               Petitioner resided in Inola, Oklahoma, at the time he filed            
          his petition.                                                               
                                       OPINION                                        
               Petitioner concedes that he received unreported income                 
          during the years in issue and does not dispute respondent’s                 
          determinations relating to his rental activity, real estate                 
          sales, wages, and helicopter business gross receipts.                       
          Accordingly, we sustain respondent’s determinations relating to             
          this unreported income.                                                     
               Petitioner contends that he believed that he was not                   
          required to file tax returns relating to the years in issue.                







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