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petitioner’s request to abate interest for tax years 1987, 1990,
and 1991.1
FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
herein by this reference. When he filed his petition, petitioner
resided in Needham, Massachusetts.
Petitioner’s Tax Years 1987 Through 1991
Petitioner has been a practicing attorney for over 40 years.
For tax years 1987 through 1991, petitioner failed to file
Federal income tax returns. In 1992, respondent issued a summons
directing petitioner to appear at the Stoneham, Massachusetts,
IRS office and produce his records relating to his 1987 through
1991 income. In response to the summons, on November 12, 1992,
petitioner produced seven or eight boxes of documents relating to
personal expenses but not to his income. By letter dated
February 8, 1993, respondent’s revenue agent notified petitioner
that the documents he had provided failed to satisfy the summons
and requested petitioner to provide bank deposit records and all
books and records relating to petitioner’s income. Subsequently,
at some unspecified date, petitioner produced what he
characterizes as “one small shoe box size of records/receipts”.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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