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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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