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hospitals reviewing and preparing Medicare cost reports.
Petitioner performed all of the auditing work himself, and the
hospitals compensated him with a percentage of the additional
payments he obtained for them. In connection with his business,
petitioner paid commissions to business associates who obtained
contracts for him, made Freedom of Information Act (FOIA)
requests, and incurred other expenses. Petitioner also paid
$75,503 of mortgage interest during this period.
Petitioner began his business before 1996, and he timely
filed his Federal income tax returns and paid his tax liabilities
every year through 1998. Petitioner filed extensions to file tax
returns for years 1999 through 2003, but he did not file returns
for those years. During an examination of the years in issue, a
revenue agent attempted to meet with petitioner and to obtain
documents from him, but petitioner was unresponsive. As a
result, respondent requested documents from third parties and
prepared returns for years 1999 through 2003 pursuant to section
6020(b). Petitioner did not make estimated tax payments or have
any withholding for those years, but he did make a $112,000
payment toward his 2000 tax liability.
On May 24, 2006, respondent issued a notice of deficiency to
petitioner for years 1999 through 2003, and petitioner timely
petitioned this Court contesting respondent’s determinations.
Petitioner strongly opposes the beliefs and actions of a
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