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appear before respondent’s revenue agent on December 7, 2004. On
December 7, 2004, petitioner filed a Form 1040, U.S. Individual
Income Tax Return, for 2000, on which he reported adjusted gross
income of $99,795 and tax due of $12,724. Petitioner also filed
his 2001 return on December 7, 2004, on which he reported
adjusted gross income of $53,582 and tax due of $1,279.
Petitioner filed his 2002 return on February 11, 2005, on which
he reported adjusted gross income of $63,564 and tax due of
$3,319.
Petitioner was not only uncooperative with respondent during
the examination of the years at issue, but he actively attempted
to prevent respondent from reconstructing his income using the
bank deposits method. On March 2, 2005, petitioner sent a letter
to Eureka Bank advising the bank not to comply with a summons
issued by respondent seeking petitioner’s financial records.
Petitioner falsely told respondent’s revenue agent that his only
bank account was with Bank of America. In a letter sent to
respondent on April 15, 2005, petitioner falsely stated that he
was not the owner of any partnership interests or rental property
during the years at issue. Furthermore, petitioner did not
maintain any books or records with respect to his income and
deductions for the years at issue.
For the year 2000, respondent determined that petitioner
received but did not report a taxable distribution from the
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