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rendering professional services to the City of Los Angeles
Department of Water and Power (DWP) and that DWP reported income
of physicians on Forms W-2, Wage and Tax Statement, and withheld
taxes and contributions, over physician objections. The letters
were evidently intended to explain petitioner’s reporting of his
professional income, and deducting of expenses, on Schedules C.
By late 1997, petitioners and respondent were engaged in
correspondence regarding changes to petitioners’ return for 1996.
By late 1998, copies of letters and other materials between the
parties indicate that both 1996 and 1997 were under
consideration.
In July of 1999, petitioners filed a Form 4506 with
respondent requesting copies of their 1996 and 1997 tax returns.
By a letter dated October 18, 1999, they were informed that “At
this time we are unable to secure a copy of your form(s) 1040 for
tax year(s) 1996 & 1997.”
Subsequently, a notice of deficiency was issued to
petitioners for the 1996 and 1997 taxable years, and a petition
in response thereto was filed with this Court. Petitioners at
that time resided in Laguna Beach, California. Respondent
answered the petition, and the case was duly calendared for
trial.
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Last modified: May 25, 2011