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if petitioner persisted in raising frivolous arguments. The
letter stated that petitioner could be required to pay a penalty
of $25,000 pursuant to section 6673.
On August 26, 2005, respondent filed respondent’s requests
for admission, which made the following contentions:
1. The petitioner lived in Blythewood, South
Carolina, at the time of the filing of his
petition in this case.
2. The petitioner did not file a federal income tax
return for the taxable year 1998.
3. Attached as Exhibit 1 is an authentic copy of the
notice of deficiency mailed to petitioner on April
2, 2004.
4. During 1998, FN Manufacturing, Inc., paid
petitioner wages in the amount of $27,011.
5. FN Manufacturing, Inc., issued petitioner a Form
W-2 for the taxable year 1998 reflecting wages in
the amount of $27,011.
6. During 1998, the State Board of Technical and
Compr. Education paid petitioner wages in the
amount of $323.
7. The State Board of Technical and Compr. Issued
petitioner a Form W-2 for the taxable year 1998
reflecting wages in the amount of $323.
8. During 1998, the State Board of Technical and
Compr. Education withheld federal income tax in
the amount of $8 from the amount paid to
petitioner.
9. Petitioner was married to Rose Siron during the
entire year of 1998.
10. Attached as Exhibit 2 is a certified literal
transcript of petitioner’s 1998 federal income tax
account.
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