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Three separate notices of deficiency were issued as follows:
On February 22, 1995, respondent issued a notice of
deficiency to petitioner determining a deficiency in her Federal
income tax for 1992 in the amount of $1,561 and an addition to
tax under section 6651(a)1 in the amount of $377.75. The notice
was mailed to petitioner at an address in Gainesville, Florida.
On October 25, 1995, respondent issued a joint notice of
deficiency to petitioner and her husband, Charles N. Scott,
determining a deficiency in their Federal income tax for 1993 in
the amount of $2,719 and an accuracy-related penalty under
section 6662(a) in the amount of $544. The notice was mailed to
P.O. Box 22338, Lake Buena Vista, Florida (the Lake Buena Vista
address).
On November 13, 1995, respondent issued a notice of
deficiency to Charles N. Scott determining a deficiency in his
Federal income tax for 1992 in the amount of $10,502 and
additions to tax in the amounts of $2,626 and $460 under sections
6651(a) and 6654, respectively. The notice was mailed to the
Lake Buena Vista address.
On February 20, 1996, petitioner and Charles N. Scott filed
a joint petition for redetermination with the Court.2 The
1 All section references are to the Internal Revenue Code
as amended. All Rule references are to the Tax Court Rules of
Practice and Procedure.
2 At the time the petition was filed, petitioner resided at
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