- 4 - position. Sokol v. Commissioner, 92 T.C. 760, 767 (1989). Petitioner did not file a tax return for his 1996 taxable year. Respondent received a Form 1099-B from Dean Witter Reynolds, Inc. (Dean Witter), which reported that petitioner realized income in the amount of $27,636 from the sale of stocks/bonds. Respondent issued a 30-day letter to petitioner on September 11, 1998, noting that respondent had not received petitioner's 1996 return and computing petitioner's income based on the Form 1099-B received from Dean Witter. The letter also asked petitioner to explain why he was not required to file a return for 1996 or to enclose information he would like the IRS to consider. Petitioner failed to respond to the 30-day letter. Respondent issued petitioner a notice of deficiency on May 7, 1999. Petitioner filed his petition on July 28, 1999. In the petition, petitioner stated: "I have never had an account with DEAN WITTER REYNOLDS INCORPORATED and I did not sell any STOCKS/BONDS in 1996". Respondent sent a letter to Dean Witter on August 25, 1999, requesting information concerning the 1996 stock/bond sale by petitioner. On August 30, 1999, respondent spoke with petitioner, who stated that he had e-mailed an information request to Dean Witter on August 27, 1999. Petitioner further stated that he had never had an account with Dean Witter, nor had he made any sales during 1996. Dean Witter did not respond toPage: Previous 1 2 3 4 5 6 7 8 Next
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