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FINDINGS OF FACT
Petitioner lived in Black Canyon City, Arizona, when he
filed the petition in this case.
Petitioner was a beneficiary in 1998-2001 of the Frank J.
Nagy Trust, administered by KeyBank National Association
(KeyBank) as trustee. Petitioner earned interest in the amounts
of $18,171 for 1998, $19,065 for 1999, $12,879 for 2000, and
$17,155 for 2001, and dividends in the amounts of $9,440 for
1998, $7,140 for 1999, $3,807 for 2000, and $5,866 for 2001 from
the trust. He received Social Security benefits of $10,821 for
1998, $10,962 for 1999, $11,226 for 2000, and $11,640 for 2001.
He received nonemployee compensation from Eniva Corp. in the
amounts of $1,565 for 2000 and $794 for 2001. No Federal income
tax was withheld for petitioner in the years in issue by any of
these payors.
Petitioner did not file Federal income tax returns for 1998-
2001 or make estimated tax payments for those years.
Respondent issued notices of deficiency to petitioner for
the years in issue. Respondent determined that petitioner
received taxable income based on documents provided by
third-party payors. Respondent determined that petitioner’s
filing status was single and allowed petitioner one exemption.
Before trial, petitioner asserted that he had a Fifth
Amendment right not to testify because to do so would have
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Last modified: May 25, 2011