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,Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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