- 5 - Blvd. (the Dallas apartment or the apartment). The Dallas apartment was their home from December 1991 until April 18, 1994. In April 1994, the Duquettes relocated to Naples, Florida. Aline made her home there, and Norman visited her there until September 1994, after which, in substantial part because of marital difficulties, he did not return to Florida. In May 1993, Norman began work for a Washington, D.C., law firm (the law firm) as an accounting consultant. The law firm treated Norman as an employee, issuing him a Form W-2, Wage and Tax Statement, for both 1993 and 1994. Those Forms W-2 show compensation of $52,060 and $155,372.50 for 1993 and 1994, respectively. During the 1994 tax year, Norman worked in Washington, D.C., on approximately 177 days. On those days, Norman resided in an apartment in Bethesda, Maryland (the Bethesda apartment). Discussion I. Validity of Notice A. Assignments of Error In the petition, petitioner assigns the following errors to respondent’s determination of a deficiency: (a) The Commissioner issued an invalid notice of deficiency as the notice is not based on an actual deficiency determination. Further, the notice is invalid because the IRS did not examine the petitioner’s tax return for the tax year ended September 30, 1994.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011