Wesley W. and Patsie Burnett - Page 7




                                        - 7 -                                         
          December 21, 2000, respondent issued the notices of deficiency to           
          petitioners for 1994, 1995, 1996, and 1997.  In connection with             
          these notices, respondent never issued to petitioners or to a               
          third party any summons for information concerning petitioners,             
          with the exception of a summons issued to Lubbock for information           
          concerning Mr. Burnett’s 1994 wages.                                        
               On the basis of an information return master file transcript           
          for Mr. Burnett that listed that he had received in 1994 taxable            
          wages totaling $19,913,5 and independent supporting documentation           
          as to those wages that respondent had requested and received from           
          Lubbock, respondent determined in the notices of deficiency for             
          1994 that petitioners had failed to report taxable wages of                 
          $19,913 for that year.  As to 1995, 1996, and 1997, respondent              
          determined in the notices of deficiency for those years that Mr.            
          Burnett had received unreported income in those years                       
          attributable to his ownership of the newspaper (newspaper                   
          income).  The agent determined the amount of newspaper income by            
          way of a four-step process, bearing in mind the fact that                   
          (1) petitioners had reported on their 1992 Federal income tax               
          return (the last Federal income tax return that they had filed as           
          owners of the newspaper) that the newspaper’s gross receipts for            
          that year were $100,736 and (2) Mr. Burnett had received during             


               5 The transcript referenced that these wages had been                  
          reported to Mr. Burnett and the Commissioner on a Form W-2, Wage            
          and Tax Statement.  That W-2 is not in the record.                          





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