-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.
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