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for the 1982 tax year to $102,665, from $8,735, which was the
amount reported by petitioners. Based on the increase in taxable
income, respondent determined a tax liability of $38,782 for the
1982 taxable year. Respondent set forth these determinations in
a Schedule of Adjustments for the 1982 tax year, which was
attached to the notice of deficiency. Also in the notice of
deficiency, respondent determined additions to tax for negli-
gence, overvaluation, and substantial understatement and
additional interest.
Respondent contends that, due to a clerical error, despite
the above adjustments, the amount of the deficiency, ultimately
reflected in the notice of deficiency, was zero. The error
occurred in the Schedule of Adjustments for the 1982 tax year.
Page 1 of the Schedule of Adjustments indicates that petitioners
reported taxable income of $8,735 for 1982. Page 2 of the
Schedule of Adjustments states that petitioners on the same
return reported $38,782 in Federal income taxes. This amount is
actually the amount that respondent claims is petitioners'
liability for taxes for 1982. Respondent placed the $38,782 in
the column for the amount of the reported liability on peti-
tioners' 1982 Federal income tax return. The amount of tax in
fact reported on petitioners' 1982 Federal income tax return was
zero. Respondent contends that an amount of zero should have
been placed in the space for total tax per return on the Schedule
of Adjustments. The zero, subtracted from the total corrected
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