- 3 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011