Gerry M. Griggs - Page 4

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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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