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lots are not sold. The entire park constitutes an economic unit.
Thus, if an investor is interested in purchasing a park, or if
the owner of an existing park desires to sell, real estate agents
such as petitioner typically would be used because of their
experience in this segment of real estate. Petitioner did not
own, develop, or manage such parks. He was simply an agent in
what appears to be a niche in the field of real estate.
A notice of deficiency was issued to petitioner for the year
2002. At the time the notice of deficiency was issued, on June
8, 2004, petitioner had not filed a Federal income tax return for
the year 2002 (the year at issue). Petitioner acknowledged that,
for several years during the 1990s, he had filed protester
Federal income tax returns. During these years, he was following
the advice of a lady who apparently specialized in filing
protester returns and in handling correspondence received by her
clients (including petitioner) from the IRS regarding such
returns. Some of the returns filed by petitioner were “zero”
returns, on which each line on the return was filled in with a
zero.
Petitioner and his wife were also “devastated”, as he
explained, over the loss of their daughter, who died unexpectedly
and for no known reason in 1994. The daughter was not married
and had two young girls. Prior to her death, she had placed one
of the girls for adoption, and, at her death, petitioner and his
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