Janet S. Shapiro - Page 3

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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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