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the year. The SSA extracts and uses the Form W-2, Wage and Tax
Statement, information received from the employer and then sends
the information electronically to the Internal Revenue Service
(Service). The Service relies on the information from the SSA
when it compares information received from third parties. The
Service used the information from the SSA to create the Automated
Substitute for Return (ASFR) Account Transcript for petitioner
for 1987. The amount of income petitioner actually earned for
teaching the course was $351. The Center's records also
indicated that petitioner earned $23,401 from the Minneapolis
Postal Data Center and $4,248 from the Veterans Administration.
The Center sent petitioner five computer-generated notices
requesting that he file a 1987 return, which notices were sent on
August 21, 1989, October 16, 1989, February 26, 1990, April 9,
1990, and May 21, 1990. Petitioner failed to respond to any of
the notices. On September 19, 1990, the Center prepared a
substitute for return for petitioner for 1987.2 In the
substitute for return procedure, the Service establishes accounts
for taxpayers who fail to file a return when the Service
anticipates that additional activity will take place, such as
assessments, payments, and credits. As to petitioner's account,
2 When a taxpayer has not filed a return, the Substitute For
Return Unit notifies the taxpayer of any proposed deficiency in
tax based on the payor information in its possession without any
assumed deductions. See sec. 6020(b).
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Last modified: May 25, 2011