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properties, and (2) that substantial revenue from the various
activities with which petitioner was involved appeared to
constitute income to petitioner personally.
Respondent also concluded that petitioner appeared to be
planning to transfer property into the name of a nominee entity
(a so-called “corporation sole”) and that this planned transfer,
among other things, indicated a “willful and deliberate attempt
[by petitioner] to conceal the receipt of taxable income and to
evade federal income taxes.”2
Based on respondent’s conclusion, on June 1, 2004,
respondent made jeopardy assessments under section 6861 against
petitioner of income tax, of additions to tax under section
6651(f) for civil fraud and under section 6654 for underpayment
of estimated tax, and of interest, relating to 1995, 1996, and
1997, as follows:
Additions to Tax
Year Tax Sec. 6651(f) Sec. 6654 Interest
1995 $44,898 $33,674 $2,434 $66,985
1996 39,747 29,810 2,116 48,268
1997 98,941 74,206 5,293 94,585
On June 3, 2004, respondent’s agent hand delivered to
petitioner at petitioner’s then current residence (viz,
29 Cummings Road, Pensacola, Florida 32503) a notice of the above
2 The use by tax protesters of abusive “corporations sole”
is well documented. See, e.g., United States v. Harkins, 355 F.
Supp. 2d 1175 (D. Or. 2004); Rev. Rul. 2004-27, 2004-1 C.B. 625.
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