Karen McManus - Page 2

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               The issues for decision are:  (1) Whether petitioner                   
          received $15,800 of unreported income in 1996 as respondent                 
          determined; and (2) whether petitioner is liable for additions to           
          tax under sections 6651(a)(1) and 6654.                                     
                                  FINDINGS OF FACT                                    
               Petitioner resided in La Habra, California, when she filed             
          the petition.                                                               
               Petitioner failed to file a Federal income tax return and              
          failed to pay Federal income taxes for the 1996 tax year.  On the           
          basis of third-party information, on April 28, 2004, respondent             
          issued a notice of deficiency to petitioner for the 1996 tax year           
          setting forth unreported non-employee income of $15,800.                    
               Petitioner timely filed a petition with the Court on July              
          29, 2004, disputing that she received unreported nonemployee                
          income in 1996.  Trial was held on this matter on March 17, 2005.           
          Although petitioner did not appear, her counsel did.                        
          Petitioner’s counsel did not introduce witnesses nor provide                
          documentary evidence to support petitioner’s position.  However,            
          petitioner’s counsel did cross-examine respondent’s sole witness.           
               During trial, respondent called one witness, Pam Wong, a tax           
          compliance officer employed by respondent.  Ms. Wong’s testimony            
          was based solely upon her memory of reviewing petitioner’s                  

               1(...continued)                                                        
          the Internal Revenue Code, as amended.  Amounts are rounded to              
          the nearest dollar.                                                         




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