Janet D. Reed - Page 2

                                        - 2 -                                         

                                   Additions to Tax                                   
                                   Sec.           Sec.           Sec.                 
          Year      Deficiency     6651(a)(1)     6653(a)(1)     6654                 
          1988      $36,638        $8,960         $1,832     $2,287                   
          1989      74,747         18,491         ---            4,995                
          1990      12,515         2,931          ---            730                  
          1991      13,084         3,271          ---            752                  
          1992      26,708         6,532          ---            1,138                
          1993      15,679         3,720          ---            620                  
               These determinations were reflected in two notices of                  
          deficiency (one for years 1988, 1989, and 1990; the other for years         
          1991, 1992, and 1993), each dated September 29, 1995.  Subsequent           
          to the issuance of the notices of deficiency, the docketing of this         
          case, and after the joinder of issues, petitioner filed delinquent          
          Federal income tax returns for each of the years at issue.  (The            
          notices of deficiency were based on income items reported by third          
          party sources and utilized the  standard  deduction.)  The                  
          delinquently filed returns incorporated the income adjustments              
          determined by the notices of deficiency and reported income in              
          excess of that contained in the notices of deficiency.  The returns         
          also reported deductions not contemplated by the notices of                 
          deficiency. Upon review by respondent, except for losses reported           
          in Schedules F, the returns were accepted as filed.                         
               Petitioner orally sought leave to amend her petition to raise          
          the issue of the Schedule F losses via a conference call held on            
          April 11, 1997.  Respondent's counsel consented to the trying of            
          this issue, and the trial proceeded accordingly.  See Rule 41(b).           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011