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3. Petitioner’s Tax Returns for 2001-04
On a date not stated in the record, petitioner received an
extension to file his 2001 return on or before October 15, 2002.
Petitioner did not file income tax returns for tax years 2002-04.
E. Notice of Deficiency for Petitioner’s Tax Year 2001 and the
Pleadings in This Case
Respondent determined a deficiency in petitioner’s income
tax for 2001 on the basis of information reported by third
parties. Respondent mailed the notice of deficiency to
petitioner on March 22, 2004. Petitioner had not filed an
individual income tax return for 2001 at that time.
Petitioner filed a petition in which he contends that he is
entitled to deduct certain expenses. Petitioner faxed a Form
1040 for 2001 to respondent’s Appeals Office less than a month
before the trial of this case. He reported income of $317,525,
which included amounts not previously reported to respondent by
third-party payers. The $317,525 consisted of: $160,000 of
wages paid by JRC; $4,033 of interest; $4 of dividends; $25,613
of capital gains; and $127,875 from rent.
On his Form 1040 for 2001, petitioner deducted the following
expenses that flowed through to him from JRC and RSC:
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