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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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