Ouan Bland - Page 4

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          attached a corresponding Form W-2, Wage and Tax Statement.                  
          Petitioner received a refund of $1,041 for 1998.                            
          1.  Nonemployee Compensation                                                
               Respondent received a Form 1099-MISC, Miscellaneous Income,            
          from San Antonio Kitchens and Baths, Inc. (SAKB), reporting that            
          $18,774 in nonemployee compensation had been paid to petitioner.            
          The Form 1099-MISC bears a Social Security number that does not             
          belong to petitioner.  Additionally, the envelope in which the              
          Form 1099-MISC was mailed bears the United States Postal Service            
          Stamp “Returned to Sender - Insufficient Address”.                          
               Respondent obtained copies of the Form 1099-MISC and copies            
          of checks from SAKB payable to petitioner.  The checks bear                 
          endorsements which appear to be petitioner’s signature.                     
               Respondent issued a notice of deficiency on January 10,                
          2001, determining that petitioner had unreported income from                
          services rendered to SAKB in the amount of $18,774, and asserting           
          an accuracy-related penalty under section 6662(a) and (b)(2) in             
          the amount of $1,099.  Petitioner timely filed a petition with              
          this Court.                                                                 
               Prior to trial, petitioner told respondent that she did not            
          perform any services for SAKB, nor did she receive any                      
          compensation from them.  She advised respondent that Mr. James              
          Fullen, with whom petitioner lives, performed services for SAKB,            

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