- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT This case was submitted under Rule 122, but other than establishing the residence of petitioner in San Diego, California, the stipulation of the parties relates only to exhibits. During the 1990s and until at least the end of 2003, petitioner solely owned and operated, through a limited liability company (LLC), an eldercare business in California and in Oregon.1 In addition to the income petitioner received relating to the eldercare business, petitioner received rental income relating to residential and commercial real property that petitioner owned in California and in Oregon. In 2001, after an audit and a criminal tax investigation by respondent relating to petitioner’s individual Federal income taxes for 1992 through 1995, petitioner was charged with and was convicted on several counts of tax evasion. As a condition of 1 References in our findings of fact to ownership, and to transfers, of real property and of other assets are not intended to constitute ultimate findings of fact as to the true legal and equitable ownership of the real property and other assets involved in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011