Patricia R. Carpentier - Page 2




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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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