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Income Tax Return, for 1999, reflecting “0” in the “corrected
amount” column of the return. Respondent audited her individual
1999 and 2000 income tax returns.
On September 10, 2003, respondent issued to petitioner a
notice of deficiency determining that petitioner received
$164,356 and $126,686.85 of taxable income for 1999 and 2000,
respectively, had tax deficiencies, and owed tax penalties.
Petitioner timely filed her petition with this Court on December
22, 2003.
II. Income
During 1999 and 2000, petitioner earned income as a real
estate sales and property manager and as the proprietor of a
business, Nature’s Herb & Tea Garden. Petitioner was also a
member of two limited liability companies (LLCs), Miroyal and
National Land Bank, for 1999 and 2000. At trial, petitioner
objected to confirming her occupations and associations stating
that the answers might incriminate her, and she chose to invoke
the Fifth Amendment as a defense.
Petitioner was warned that she should assume she had the
burden of proof and was given the opportunity to present her case
to the Court; however, she chose not to do so. She presented no
evidence, nor did she offer any witnesses on her behalf. In
resting her case, petitioner stated: “I don’t have any witnesses
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