- 16 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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