Helen S. Healer - Page 1

                                   115 T.C. No. 24                                    

                               UNITED STATES TAX COURT                                

                           HELEN S. HEALER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No.  12867-99.                Filed October 13, 2000.           

                    Petitioner (P) failed to file timely a Federal                    
               income tax (tax) return (return) for 1996.  On Apr. 28,                
               1999, respondent (R) timely mailed to P a notice of                    
               deficiency (notice) which included a substitute for                    
               return prepared by R pursuant to sec. 6020(b)(1),                      
               I.R.C., for P’s tax year 1996 (R’s substitute for                      
               return for P’s tax year 1996).  As of the date of the                  
               mailing of the notice, P had not filed a return for                    
               1996.  On July 16, 1999, P signed a return for 1996                    
               (P’s 1996 return), which was received by R on July 19,                 
               1999.  On Aug. 4, 1999, after the petition was filed in                
               this case, P signed an amended return for 1996 (P’s                    
               amended 1996 return), which she submitted to R.  In P’s                
               1996 return, P’s amended 1996 return, and the petition,                
               P disputed each determination in the notice that ap-                   
               pears in R’s substitute for return for P’s tax year                    
               1996 (except P conceded in the petition and P’s amended                
               1996 return that her prepayment credits for 1996, which                
               are attributable to estimated tax payments for that                    
               year, total $30,480).  The parties now agree that,                     

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