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During 1996 and 1997, petitioner maintained an account with
Maynard Savings Bank (Maynard). Utilizing Form 1099, Maynard
reported the payment of interest to petitioner for the years in
issue as follows:
Year Amount
1996 $5
1997 30
Petitioner was unmarried throughout 1996. Petitioner
married in April 1997 and remained married for the balance of
that year.
Petitioner did not file a Federal income tax return for
either 1996 or 1997. Petitioner had no prepayments of tax,
either through withholding or the making of estimated quarterly
tax payments during the course of the taxable year, for either
1996 or 1997.
In or about September 1999, respondent prepared returns for
petitioner for 1996 and 1997 pursuant to the authority granted
respondent in section 6020(b).
On March 17, 2000, respondent mailed a notice of deficiency
to petitioner determining the deficiencies in income taxes and
the additions to tax that are in issue herein. See sec. 6212(a).
The deficiencies are based on respondent's determination that
petitioner failed to report compensation from Transco and
interest from Maynard in the amounts reported by the payors. In
computing the deficiencies, respondent utilized the tax table
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