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6673(a)(1). By notice of deficiency, respondent determined a
deficiency of $7,149 and an accuracy-related penalty of $813 with
respect to petitioner’s 1997 Federal income tax.
Background
In the notice of deficiency, respondent determined, on the
basis of income reported by third-party payers, that petitioner
failed to report wage income of $32,939 from Empire Hospital,
nonemployee compensation of $7,532 from Douglas GR, and interest
income of $29 from United Health for 1997. Respondent also
determined self-employment tax adjustments and an accuracy-
related penalty.
On August 21, 2000, petitioner invoked the jurisdiction of
this Court by timely filing an imperfect petition.
On September 1, 2000, respondent filed a motion to dismiss
for failure to state a claim and to impose sanctions pursuant to
section 6673 (respondent’s first motion).
On September 5, 2000, the Court ordered petitioner to file
an amended petition in order to comply with the Rules of the
Court as to the form and content of a proper petition and
calendared respondent’s first motion for a hearing on October 4,
2000, in Washington, D.C.
On October 2, 2000, petitioner filed an amended petition
virtually identical to the original petition. At the time she
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