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6673.1 In this protracted case that has extended over a 5-year
period, petitioner has done little to address the underlying
merits of respondent’s determination. On November 6, 1995,
respondent issued two notices of deficiency determining Federal
income tax deficiencies and additions to tax for failure to file
returns and failure to pay estimated taxes for petitioner’s 1989
through 1993 tax years, as follows:
Income Tax Additions to Tax
Year Deficiencies Sec. 6651(a)(1) Sec. 6654
1989 $393,505 $98,376 $26,466
1990 55,055 13,764 3,623
1991 13,284 3,321 765
1992 42,031 10,508 1,833
1993 15,416 3,854 646
In great part, respondent relied on Forms 1099 reflecting
proceeds from stock transactions and dividend and interest income
that were ostensibly attributable to petitioner. Petitioner
alleged error, claiming, in essence, that the proceeds reflected
on the Forms 1099 did not result in income taxable to her.
Without petitioner’s cooperation, respondent has been able
to obtain information that supports petitioner’s allegation that
she was not obligated to report the proceeds from stock
transactions reflected on Forms 1099. In the course of
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended and in effect for the
taxable periods under consideration, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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