Steven R. Olmos - Page 6




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          23, 2006, the Court set petitioner’s case for a date and time                
          certain of 10:00 a.m. EST on Friday, March 31, 2006.                         
               When petitioner’s case was called for trial on March 31,                
          2006, petitioner did not appear.  Instead, George E. Harp (Mr.               
          Harp) appeared on petitioner’s behalf, and the Court filed Mr.               
          Harp’s entry of appearance.  Although Mr. Harp offered no                    
          evidence at trial regarding petitioner’s unreported income,3 Mr.             
          Harp objected to all but one of respondent’s exhibits.  After                
          hearing argument on the objections, we overruled petitioner’s                
          objections and admitted the exhibits.                                        
                                       OPINION                                         
          I.   Unreported Income                                                       
               Section 61(a) defines gross income for purposes of                      
          calculating taxable income as “all income from whatever source               
          derived”.  Respondent determined petitioner received gross income            
          in the form of taxable interest and medical and healthcare                   
          payments, and that petitioner failed to file a 2001 Federal                  
          income tax return reporting these items.                                     






               3  Petitioner did introduce into evidence a letter from                 
          respondent’s counsel outlining documents respondent intended to              
          use at trial.  It is unclear why petitioner introduced this                  
          letter into evidence, as it does not relate to any issue and was             
          not cited by petitioner on brief.                                            






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