- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011