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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