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Respondent determined petitioner’s documentation did not
substantiate the business deductions at issue and on January 4,
2006, mailed petitioner a notice of deficiency disallowing these
deductions. Petitioner timely filed his petition on March 30,
2006.
On August 15, 2006, respondent’s counsel mailed petitioner a
letter requesting a meeting to discuss the case and any
documentation petitioner wanted considered. In response, on
August 17, 2006, petitioner mailed a letter stating that he would
not meet with respondent’s counsel before trial, that respondent
had failed to comply with the Paperwork Reduction Act, and that
respondent lacked the authority to assert income tax
deficiencies. On September 29, 2006, respondent’s counsel mailed
another letter to petitioner requesting a meeting to discuss the
case, discuss any additional information petitioner wanted
considered, and prepare a stipulation of facts. Petitioner did
not respond to the September letter or meet with respondent’s
counsel before trial. Petitioner signed the stipulation of facts
on the day of trial, October 25, 2006.
OPINION
I. Whether Petitioner Was Carrying On a Business in 2003
Petitioner contends the business deductions at issue were
directly related to the operation of his computer software
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