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Petitioner and the Appeals officer exchanged additional
correspondence. At some point during that time, respondent
learned that petitioner was president of an active California
corporation (the corporation). This information is not listed in
the OIC or in petitioner’s letters to the Appeals officer.
Respondent sent petitioner a letter in August 2004 again
requesting his employment history, as well as “Financial and
other records with respect to any related corporations in which
you were an officer or shareholder.”
Petitioner claims he did not receive respondent’s August
2004 letter. He acknowledges, however, that he did not provide
respondent with certain financial information, including
information about the corporation, verification of Ms. Bernd’s
income, and a breakdown of the respective contributions toward
living expenses that he and Ms. Bernd made. He also concedes his
OIC does not list any constructive income in the form of reduced
rent that he received from Ms. Bernd in exchange for performing
services for her.
In November 2004, respondent issued petitioner a notice of
determination sustaining the filing of the notice of Federal tax
lien. The notice of determination states: (1) Petitioner failed
to provide adequate financial information, and (2) petitioner has
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