- 2 - In a statutory notice of deficiency dated February 27, 1997, respondent determined a deficiency in petitioner's Federal income tax for 1994 in the amount of $3,934. The issues for decision are: (1) Whether respondent is bound by the contents of a report issued by his Problem Resolution Officer subsequent to the issuance of the statutory notice of deficiency; and (2) whether this Court has jurisdiction to consider petitioner's claim for an abatement of interest. Some of the facts have been stipulated and are so found. The stipulations of fact and attached exhibits are incorporated herein by this reference. Petitioner resided in Hereford, Arizona, on the date the petition was filed in this case. Petitioner timely filed his Federal income tax return for 1994 on which he correctly reported his filing status as single. In the statutory notice of deficiency in this case respondent determined that petitioner received but failed to report on his 1994 return the following amounts of income: Pensions and annuities $2,359 IRA distributions 3,216 Taxable Social Security benefits 7,188 Gambling income 26 With respect to the unreported pension and annuity income which petitioner received from the Office of Personnel Management Retirement Programs (the OPM Retirement Program), respondent concedes that petitioner is entitled to exclude from his gross income any portion of the amount received which is attributablePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011