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notice of deficiency was issued timely for the 1995 taxable year.
Because of this Court’s order as to the deemed admissions and our
ruling that the notice of deficiency was timely, respondent’s
determinations as to the 1995 taxable year are sustained.
We turn to petitioner’s 1996 taxable year. On April 15,
1997, petitioner filed his 1996 individual Federal tax return.
Petitioner reported “wages, salaries, tips, etc.” of zero.
Petitioner also reported adjusted gross income, taxable income,
and total tax of zero. Petitioner attached a two-page document
to his 1996 return, which was essentially identical to the two-
page document attached to his 1995 return.
In the notice of deficiency for the 1996 taxable year,
respondent determined that petitioner had total unreported gross
income in the amount of $9,051 from various specific sources.
This included the following items: (1) Interest income in the
amounts of $108 and $11 from Mather Federal Credit Union and
Countrywide, respectively; (2) early distribution from an
individual retirement account in the amount of $7,017 from First
National Bank; (3) nonemployee compensation in the amount of $690
from Nader Afrooz; and (4) rental income in the amount of $1,225
from Coldwell Banker. Respondent adjusted petitioner’s self-
employment tax and allowed him a corresponding deduction.
A Form 1065, U.S. Partnership Return of Income, was timely
filed for Quality Sweeping & Steam Cleaning (Quality) for the
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