- 3 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011