- 9 - had sufficient information to determine his precise tax liability for 2002, he did not attempt to estimate the omitted income he received during the year at issue. Petitioner could have approximated his investment income based on past annual reports or previously filed returns. Knowing that the accounts that produced the omitted income existed, petitioner could have contacted the businesses where these accounts were located and requested that copies of the Forms 1099-B and 1099-DIV or duplicates thereof be sent to him. Even if petitioner were unable to obtain any information regarding the omitted income prior to filing his income tax return for 2002, he could have attached a statement to the return explaining the relevant facts and circumstances and indicating that an amended return would later be filed. Instead, petitioner relied upon his father to assess his tax liability and ignored the matter until respondent issued the notice of deficiency. While the Court sympathizes with petitioner and understands the difficulties, financial and otherwise, he encountered from his bacterial infection and Mr. Vicknair’s death, those 3(...continued) brokers who managed the accounts. These brokers provided Mr. Becnel and his family with annual updates concerning their accounts’ performances. Because most people monitor their investments, the Court inquired as to why petitioner’s financial affairs were not so monitored. Mr. Becnel addressed this concern by testifying: “Well, when you do the tobacco settlement, and you settle the case for $287 billion, and you get paid four times a year, money is irrelevant.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011