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Respondent determined a deficiency in petitioner’s Federal
income tax of $17,488 and additions to tax under section
6651(a)(1) of $1,511.77, under section 6651(a)(2) of $839.87, and
under section 6654(a) of $293.93 for the taxable year 1996.
The issue remaining for decision is whether petitioner is
entitled to a refund for an overpayment of $6,601 for the taxable
year 1996.1
At the time of filing the petition herein, petitioner
resided at Chestnut Hill, Massachusetts.
Petitioner did not file a Federal income tax return for the
taxable year 1996. Respondent issued a notice of deficiency on
August 11, 1999. The notice determined that petitioner received
items of income such as wages, dividends, and gains on the sale
of stock and failed to report such on an income tax return for
1996. Respondent allowed petitioner the standard deduction under
section 63(c).
Petitioner timely filed a petition with this Court disputing
the deficiency and arguing that respondent failed to take into
account various losses from rental property and two “S”
corporations. Petitioner also asserted that respondent did not
1 The parties agree that petitioner’s withholding of
$10,769 exceeds her income tax liability of $4,168. Respondent
concedes that the additions to tax under secs. 6651(a)(1),
6651(a)(2), and 6654(a) are inapplicable due to the excess
withholding credits.
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