- 3 - Petitioner is a practicing physician specializing in adult and pediatric urology. He operates his own medical practice, David L. Samuel, M.D., A Professional Medical Corporation. Petitioner is also a partner in Pontchartrain Lithotripsy, LLC. Prior to starting his own practice, petitioner practiced with another urologist until sometime in 2002. Beginning on February 3, 2003, petitioner began filing delinquent individual income tax returns for 1996-2002. The dates on which petitioner filed the returns and the Internal Revenue Service (IRS) assessed the taxes due are as follows: Year Date Return Filed Date Taxes Assessed 1996 January 26, 2004 March 8, 2004 1997 February 3, 2003 March 24, 2003 1998 February 3, 2003 March 31, 2003 1999 February 3, 2003 March 24, 2003 2000 February 3, 2003 March 3, 2003 2001 February 3, 2003 March 3, 2003 2002 October 3, 2003 November 3, 2003 The so-called “TXMODA” computer transcripts of petitioner’s IRS accounts for each of these years show adjusted gross income posted from petitioner’s tax returns as follows: Year AGI 1996 $187,108 1997 220,250 1998 205,492 1999 303,558 2000 140,213 2001 177,566 2002 211,991Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007