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order, we also granted petitioner’s motion for leave to file an
amended petition out of time, and we directed that petitioner’s
amended petition be filed as of August 16, 2004.
A notice setting case for trial during the Court’s Oklahoma
City, Oklahoma, trial session beginning March 6, 2006, was served
on petitioner on October 4, 2005. On March 6, 2006, we called
petitioner’s case to determine the status of the case and to set a
trial date. Neither petitioner nor a representative appeared. We
scheduled trial in petitioner’s case for March 7, 2006.
When petitioner’s case was called for trial on March 7,
2006, petitioner’s attorney appeared, but petitioner did not.
Although petitioner’s attorney offered no evidence at trial, he
objected to three of respondent’s exhibits. After hearing
argument on the objections, we overruled petitioner’s objections
and admitted the exhibits.
OPINION
I. Unreported Income
A. Burden of Production
Section 61(a) defines gross income for purposes of
calculating taxable income as “all income from whatever source
derived”. Respondent determined that petitioner received gross
income from VALIC and Nationwide, which petitioner failed to
report on a Federal income tax return for 2000.
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