George E. Harp - Page 2




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          discretion in sustaining the proposed collection actions and                
          whether the Court should impose against petitioner a penalty                
          under section 6673(a).                                                      
                                  FINDINGS OF FACT                                    
               At the time he filed his petition, petitioner resided in               
          Shreveport, Louisiana.                                                      
               Petitioner is an attorney admitted to practice before this             
          Court.  He has represented at least two taxpayers before the                
          Court.  See Olmos v. Commissioner, T.C. Memo. 2007-82; Heers v.             
          Commissioner, T.C. Memo. 2007-10.                                           
               Petitioner failed to timely file Federal income tax returns            
          for 1995 through 2000 (years at issue).  During the examination             
          of the years at issue, petitioner submitted tax returns reporting           
          all zeroes and attached documents entitled “Asseveration of                 
          Claimed Gross Income” and “Statement and Asseveration of                    
          Exclusion of Remuneration from Gross Income”.  In the returns and           
          attachments, petitioner argued that his income was not includable           
          in gross income and raised various tax-protester arguments.                 
          After respondent received petitioner’s returns, respondent used             
          the bank deposits method to reconstruct petitioner’s income.2               


               1(...continued)                                                        
          are rounded to the nearest dollar.                                          
               2  Respondent issued summonses to various banks, ordering              
          the banks to produce petitioner’s bank records for the years at             
          issue.  Prior to the issuance of the notice of deficiency,                  
                                                             (continued...)           





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