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