Cliff Connors - Page 6

                                        - 6 -                                         
          Quadrino & Schwartz asserted a lien of 50 percent against the               
          recovery paid by Connecticut General, asserted a lien against               
          every monthly disability benefit payment paid by Connecticut                
          General to petitioner, and maintained that amount in the escrow             
          account until resolution of the dispute.                                    
               Quadrino & Schwartz maintained the escrow account at                   
          Citibank in 2002.  The escrow account schedule reflects that                
          interest of $3,186.49 was earned on the account from July 3,                
          2002, through February 14, 2005.  Petitioner also maintained an             
          individual bank account at Citibank.                                        
               Petitioner was married to Lucy Lejin Qi Connors                        
          (Mrs. Connors) on February 14, 2001.  Neither petitioner nor                
          Mrs. Connors filed a Federal income tax return for 2002 or paid             
          any taxes for that year.  A substitute return under section                 
          6020(b) was prepared by the Internal Revenue Service for that               
          year on February 1, 2005.  Petitioner was a cash basis taxpayer             
          in 2002.                                                                    
          Procedural Matters                                                          
               Respondent sent a notice of deficiency for 2002 to                     
          petitioner on May 27, 2005.  Petitioner filed the petition in               
          this case on August 15, 2005.  The petition placed in issue only            
          the insurance proceeds, alleging:                                           
                    4.  The determination of the tax set forth in the                 
               said notice of deficiency is based upon the following                  

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011