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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
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