The taxpayer had also failed to produce the information the precept required in respect of his building society accounts.
Since 1994, when the new Government took over, taxpayers have failed to pay $1.2 billion they owed.
Individual taxpayers failed to pay up to $353 billion in taxes in 2001, according to a study released yesterday by the Internal Revenue Service.
The agency said that, if taxpayers failed to include the information on this year's tax forms, they would get warning letters but would not face fines.
Because taxpayers failed the second prong of the test, the court did not apply the third requirement to the facts of the case.
Strict penalties apply when taxpayers fail to disclose their participation in certain "reportable transactions."
If taxpayers failed to withhold enough to match their tax liability, what they will owe in 1987 taxes may come as a shock.
Many taxpayers fail to realize that passive losses are subject to limits.
If the taxpayer fails to make the payments, the offer will be returned to the taxpayer.
That means identifying and isolating trouble early, rather than suppressing market forces and leaving the taxpayers responsible when regulation fails.