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Background
Administrative History
The Form 4340, Certificate of Assessments, Payments, and
Other Specified Matters, for petitioner’s 2001 tax year shows
that the Internal Revenue Service (IRS) has no record of
receiving a tax return from petitioner for the year. Respondent
determined in the statutory notice of deficiency that petitioner
had failed to file a Federal income tax return for 2001. After
the petition for redetermination was filed, the case was assigned
to the office of Appeals. The Appeals Office requested that
petitioner provide a copy of a completed 2001 income tax return.
Petitioner did not do so. The case was subsequently transferred
to respondent’s counsel for trial or settlement.
Document Request by Counsel
Respondent’s counsel requested that petitioner provide a
completed 2001 income tax return and supporting documentation for
the items on the return. There was no response. Respondent
served petitioner with a Request for Production of Documents
(Request). The Request asked for: (1) Books and records that
petitioner intended to introduce into evidence at trial for 2001,
(2) business and personal bank statements for the year, (3)
documents evidencing the receipt of income, (4) documents
evidencing the expense reimbursement policy of petitioner’s
employer, and (5) documentary evidence bearing on the additions
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Last modified: May 25, 2011