- 14 - 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 8 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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