-3-
Petitioner worked for Fairchild Data Corp. (Fairchild) for
about 12 years. Fairchild withheld from petitioner's wages
Federal income taxes of $4,780 for 1992, $6,939 for 1993, and
$7,089 for 1994. In July 1995, Fairchild laid off petitioner.
Fairchild paid petitioner $36,119 in 1995, of which $4,671 was
withheld for Federal income taxes. About $14,000 of the $36,119
was severance pay.
In 1995, petitioner had an individual retirement account
(IRA) at Mellon Bank N.A., trustee for Fairchild Industries, Inc.
Sometime in 1995, respondent served Mellon Bank or Fairchild with
a notice of levy against the account, and Mellon Bank distributed
$26,861 from the account to respondent. Of this amount, $5,372
was withheld for Federal income taxes. Mellon Bank reported to
respondent that it had made a $26,861 taxable distribution from
petitioner's IRA in 1995.
B. Petitioner's Federal Income Tax Returns for 1992-95 and the
Notices of Deficiency
Petitioner did not file Federal income tax returns (Forms
1040) for 1992, 1993, 1994, and 1995.
Fairchild reported on an information return sent to
respondent that it had paid petitioner taxable wages of $36,119
in 1995.
On October 24, 1997, respondent sent two notices of
deficiency to petitioner: one for 1992, 1993, and 1994, and one
for 1995. Respondent determined that petitioner's filing status
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