Shirley J. Raney - Page 4




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          The Bank of New York.  In 1995, petitioner received $3,693 from             
          the Fireman’s Fund Retirement Plan.                                         
               Petitioner provided the Fireman’s Fund with Form W-4,                  
          Employee’s Withholding Allowance Certificate, dated May 5, 1992,            
          on which she claimed 10 withholding allowances.  Petitioner                 
          provided Montgomery Ward with Form W-4, dated July 29, 1994, on             
          which she claimed eight withholding allowances.  Petitioner                 
          provided Data Input Services with Form W-4, dated October 10,               
          1994, on which she claimed eight withholding allowances.                    
          Petitioner provided Physicians Healthcare with Form W-4, dated              
          November 28, 1994, on which she claimed eight withholding                   
          allowances.  Petitioner provided Burns & Wilcox with Form W-4,              
          dated July 19, 1995, on which she claimed eight withholding                 
          allowances.  Petitioner’s employers withheld Federal income taxes           
          from her wages in the amounts of $641.36, $0.00, $696.41,                   
          $117.61, and $129.51 for the years 1992, 1993, 1994, 1995, and              
          1996, respectively.  Petitioner made no estimated tax payments              
          for the years in issue.                                                     
               Petitioner sent Forms 1040, U.S. Individual Income Tax                 
          Return, to respondent for the years in issue.  The Forms 1040               
          were received by the Internal Revenue Service on December 17,               
          1997.  On those Forms 1040, petitioner reported no income.                  
          Respondent did not accept the above-referenced Forms 1040 as tax            








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