- 12 - paid by the insurance company as provided by the insurance policy; he actually received a reduced amount of funds in 2002 from his federal court case, and lawyers therein withheld most of said funds pending outcome of the other case on attorney fees for the federal court case; further, he did indeed pay premiums for health and disability insurance coverage through his employer, Time Warner; and that, if any deficiency is sustained against him, then he is entitled to such exemptions, credits and deductions including earned income credit as allowed for a married man with three children and others that apply to his circumstances. There were no documents, records, or affidavits attached to the offer of proof to substantiate any of the statements made therein. Additionally, petitioner never sought to be relieved of the deemed admissions in this case. The deemed admissions include that petitioner paid no premiums toward his insurance policy, that Connecticut General’s 2002 payment of $269,474 to petitioner was in satisfaction of the insurance company’s requirement to pay to petitioner 66-2/3 percent of his salary as a disability payment, that the 2002 Form W-2 for $269,474 included no Federal income tax withholding, that petitioner earned interest income of $972 and $15 from Citibank in 2002 on the escrow account and a U.S. savings bond, respectively, that petitioner’s failure to file timely the 2002 tax return was not due to reasonable cause and was due to willful neglect, and that the section 6651(a)(1) and (2) additions to tax are applicable for 2002. Respondent objected to the motion to amend the petition and to reopening the record. By order dated June 27, 2006, the CourtPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011