Creed J. Pearson - Page 4




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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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