Chester H. and Michelle R. Rossman - Page 16

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          services at NTS and FMG conferences, providing consulting                   
          services, and engaging in several business activities.                      
               Petitioner never filed tax returns for any of his                      
          businesses.  Ultimately, he reported some of the business income            
          on his own returns.  He did not file any returns for the years in           
          issue until 2004, several months after the statutory notice of              
          deficiency underlying this case had been mailed determining                 
          deficiencies in his income tax and section 6651(f) additions to             
          tax.                                                                        
               By stipulation, petitioner conceded gross receipts from his            
          consulting business DSG of $76,090 for 1997, $178,747 for 1998,             
          $303,225 for 1999, and $198,990 for 2000, and at trial,                     
          petitioner admitted he significantly understated gross income for           
          2000 on the Form 1040 he submitted to respondent in March or                
          April of 2004.  Furthermore, when Kevin Davis (Agent Davis), an             
          IRS agent, performed an examination of petitioner’s records, the            
          examination revealed that petitioner’s tax liability should have            
          been higher than the amounts shown on his Forms 1040 for 1998               
          through 2000.10  Lastly, petitioner’s self-serving statement that           
          he agreed to the stipulated deficiency amounts for the years in             
          issue only because he was “worn out” from his dealings with the             
          IRS fails to persuade the Court that the acknowledged tax                   


               10 At trial, Agent Davis could not remember whether this               
          situation also pertained to the 1997 taxable year.                          





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