-5- for 2001 and 2002, and therefore was liable for increased deficiencies, increased penalties under section 6663, and increased additions to tax under section 6651(a)(1).5 On November 15, 2006, trial was held in San Francisco, California. During the years at issue, petitioner was an employee of Linotext America, Inc., and self-employed as a printing salesman doing business as Ray Vogt Enterprises and Springboard Ltd. Trust. Petitioner created Springboard Ltd. Trust during 2002 to operate his printing business and to pay certain personal expenses. On February 1, 1999, and January 1, 2003, petitioner filed Forms W-4, Employee’s Withholding Allowance Certificate, falsely stating, under penalty of perjury, he was exempt from withholding taxes. On January 20, 2004, respondent advised petitioner that respondent had received information that he might be involved with American Rights Litigators (ARL), an abusive tax avoidance scheme. On February 4, 2004, petitioner mailed respondent a letter in which he falsely denied involvement with ARL. On May 11, 2004, respondent served a summons on petitioner requesting that he appear on June 2, 2004, to answer certain questions and provide records regarding his income taxes. Petitioner did not comply with the summons. On November 30, 2004, the U.S. District Court, Northern District of California ordered petitioner to 5On brief, respondent conceded the additional unreported income for 2002.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007