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Until 1994, when he was placed on short-term disability, the
petitioner was employed as an insurance agent for Metropolitan
Life and Affiliated Companies, Inc. (Met Life). Petitioner--who
holds an M.B.A. degree--was previously employed by Met Life as a
systems analyst and a financial planner. Petitioner also has
been employed as an investment broker and is a registered
investment advisor.
Petitioner suffers from serious medical conditions and
physical impairments. Petitioner was placed on short-term
disability in 1994, whereupon he was periodically examined for 2
years before he was placed on long-term disability. He has
remained on long-term disability continuously since 1996.
Petitioner failed to file a tax return for 2000. Respondent
prepared a substitute return and determined petitioner’s income
tax liability and accordingly, an amount in deficiency, based on
income as reported by third-party payers. Petitioner did not
make any estimated income tax payments for 2000.
At a partial trial on June 1, 2004, petitioner appeared
before this Court, and--for the first time--delivered to
respondent a completed Federal income tax return for 2000. Upon
discovering that respondent had not reviewed the material
contained in petitioner’s return, this Court retained
jurisdiction, issuing an order for both parties to submit written
status reports. However, before petitioner offered his completed
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