Chester H. and Michelle R. Rossman - Page 9

                                        - 9 -                                         
          his supervisor.  On May 29, 2002, the IRS issued to petitioner a            
          statutory notice of deficiency for 1995 and 1996.  In response,             
          petitioner filed a petition with the Court on September 3, 2002,            
          at docket No. 14104-02.  On December 3, 2003, pursuant to a                 
          stipulation of the parties, this Court entered a decision in that           
          case that petitioner owed a deficiency and addition to tax and              
          penalty under sections 6651(a)(1) and 6662(a) for 1995 and a                
          deficiency and an addition to tax under section 6651(a)(1) for              
          1996.                                                                       
          Years in Issue:  1997, 1998, 1999, and 2000                                 
               Petitioner had gross receipts from consulting for the years            
          1997, 1998, 1999, and 2000 of $76,090, $178,747, $303,225, and              
          $198,990, respectively.  On August 21, 2003, when respondent                
          issued petitioner a statutory notice of deficiency for each of              
          these years, petitioner had not yet filed a Federal income tax              
          return for any of them.  Petitioner filed a timely petition on              
          November 24, 2003, and thereafter provided Forms 1040 for 1997              
          through 2000 to respondent in March and April, 2004.                        
               The Forms 1040 reported less tax due than had been                     
          determined by the notice of deficiency.  Following prolonged                
          negotiation and petitioner’s presentation of additional evidence            
          and substantiation in support of his reporting positions, the               
          parties agreed to the following:  The 1997 deficiency of $28,074            
          was reduced to $14,062; the 1998 deficiency of $66,821 was                  






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011