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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 to
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