Helen S. Healer - Page 3

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                                             Additions to Tax                         
           Year    Deficiency      Sec. 6651(a)(1)       Sec. 6651(a)(2)              
           1996    $34,417.00          $885.82               $433.07                  
               The only issue remaining for decision is whether petitioner            
          is entitled to a refund of her overpayment of tax for 1996.  We             
          hold that she is not.                                                       
               This case was submitted fully stipulated.  The facts that              
          have been stipulated are so found.  The following background                
          reflects facts stipulated by the parties and matters asserted on            
          brief that the parties do not dispute.                                      
               Petitioner’s mailing address was in South Natick, Massachu-            
          setts, at the time the petition was filed.                                  
               Petitioner received an automatic extension of time until               
          August 15, 1997, within which to file her tax return (return) for           
          1996.  Thereafter, she received a second extension until October            
          15, 1997, within which to file that return.  Petitioner did not             
          timely file her 1996 return on or before October 15, 1997.                  
               On April 28, 1999, respondent timely mailed to petitioner a            
          notice of deficiency (notice) for 1996, in which respondent made            
          the determinations that we have described above and that we                 
          describe below.  As of the date of the mailing of the notice,               
          petitioner had not filed a return for 1996.                                 
               Included as part of the notice that respondent issued to               

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