-6- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007