Wm. Dennis Gray - Page 5




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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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