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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.
Background
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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