Astrida Terauds - Page 14

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               The background on this issue is somewhat unusual.                      
          Petitioner and her daughter Sandra held joint title to the                  
          corporate stock addressed earlier in this opinion in connection             
          with the capital gain issue.  Petitioner and Sandra also held               
          joint title to several interest-bearing accounts in several banks           
          as well as certificates of deposit.  For each of these accounts             
          and securities, the reports to the Internal Revenue Service (IRS)           
          by the payers of interest and dividends, as well as the reports             
          of the gross sales proceeds on the sales of corporate stocks                
          during 1986, listed Sandra as the recipient or payee of the                 
          reported amounts.  However, for the years 1985, 1986, and 1987,             
          Sandra did not report any of these amounts on her Federal income            
          tax returns.  Notices of deficiency were issued to Sandra for               
          these 3 years with respect to the unreported amounts.  Sandra did           
          not pay the deficiencies determined in the notices of deficiency            
          and took no action to challenge the determinations of respondent            
          in these notices of deficiency.  Accordingly, Sandra was assessed           
          for deficiencies in tax in accordance with the amounts determined           
          in the notices of deficiency.8  Pursuant to these assessments,              
          the IRS levied on several of the bank accounts that were in the             
          joint names of Sandra and petitioner.  Sizeable amounts of money            

               The notices of deficiency to Sandra and the assessments                
          against her were not introduced into evidence.  These factual               
          assertions are based solely on statements to the Court by counsel           
          for respondent, which the Court construes as factual admissions             
          for purposes of this case.                                                  

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