Helen S. Healer - Page 4

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          petitioner for her tax year 1996 was a three-page document                  
          entitled “PROPOSED INDIVIDUAL INCOME TAX ASSESSMENT” which was              
          dated January 4, 1999, and the first page of which contained the            
          heading “TAX CALCULATION SUMMARY”.  Respondent had originally               
          prepared that document with respect to petitioner’s tax year 1996           
          in accordance with respondent’s automated substitute for return             
          procedures pursuant to respondent’s authority under section                 
          6020(b)(1).  (For convenience, we shall refer to the three-page             
          document included as part of the notice that respondent issued to           
          petitioner for 1996 as respondent’s substitute for return for               
          petitioner’s tax year 1996.)                                                
               In respondent’s substitute for return for petitioner’s tax             
          year 1996, respondent determined, inter alia, that for 1996                 
          petitioner’s “total income” was $133,156, that there were no                
          adjustments to petitioner’s “total income”, and that, conse-                
          quently, petitioner’s “adjusted gross income” was equal to the              
          “total income” determined by respondent for that year (i.e.,                
          $133,156).  Respondent further determined in respondent’s substi-           
          tute for return for petitioner’s tax year 1996 that petitioner is           
          entitled to one personal exemption of $2,193 and a standard                 
          deduction, including a deduction for individuals age 65 or older,           
          of $5,000, that petitioner’s “taxable income” for 1996 equaled              
          $125,963, that the tax before credits on that taxable income is             
          $34,417, and that the tax after prepayment credits of $30,480 is            

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