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Kupersmit) received on account of his disability. On July 28,
1997, petitioners wrote to the Court and requested permission to
combine tax years 1994, 1995, and 1996 in one proceeding because
the same issues were involved in all 3 years. Petitioners
received a written response dated August 5, 1997, from a staff
attorney at the Court stating that they could not amend their
petition to include tax years for which they had not received a
notice of deficiency.
Thereafter petitioners received a notice of deficiency with
respect to their 1995 tax year. Petitioners and respondent
reached agreements with respect to their 1994 and 1995 tax years,
and decisions were entered by the Court in February 1998.
Petitioners were first contacted by the Internal Revenue
Service (IRS) with respect to their 1996 Federal income tax
return on July 29, 1998, and a notice of deficiency was issued
for 1996 on November 18, 1998. With respect to their 1997
return, petitioners were first contacted by the IRS on January
13, 1999, and a notice of deficiency was issued for 1997 on April
7, 1999. The notices of deficiency for petitioners’ 1996 and
1997 tax years were based on adjustments to petitioners’ income
for unreported gambling winnings and taxable Social Security
benefits, similar to the adjustments made to petitioners’ 1994
and 1995 tax years.
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