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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.
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