[*17]
contact her. She also attempted to contact petitioner via telephone but received no response. Revenue Agent AlyceFaye eventually held a telephone conference with petitioner and an individual representing himself as petitioner’s attorney. During the call Revenue Agent AlyceFaye informed petitioner that she had no records of petitioner’s filing tax returns for 1998-99 and 2000-06. Petitioner repeatedly stated that she did not have any taxable income and therefore was not required to file returns for those years.
Petitioner did not provide any records or other information to respondent either before or after the telephone conference. Consequently, respondent used the records seized during the criminal investigation to conduct the examination for petitioner’s 1998-99 and 2000-04 tax years and summoned bank records to conduct the examination for petitioner’s 2004-06 tax years.[1]
IX. Petitioner’s Tax Reporting and the Notice of Deficiency
Petitioner and Mr. Hovind did not file joint Federal income tax returns for the years at issue. In response to respondent’s examination and after respondent’s issuance of a so-called 30-day letter, petitioner, on September 5, 2008, untimely filed tax returns for the years at issue. In addition to her involvement with CSE,
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- ↑ With respect to petitioner’s 2004 taxable year, the bank records seized during the criminal investigation covered approximately the first six months of 2004.
