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Paid to intervenor:
NC Admin. Office of the Courts $14,399
Smith Anderson, et al. 805
Twiggs Abrams Strickland & Trehy 2,595
Paid to petitioner:
Educational Testing Service 454
National Institute of Corrections 1,650
The calculation of the amount of the deficiency appearing in the
notice of deficiency is not in the record. Respondent concedes
that both of the amounts paid to petitioner and the $2,595 amount
paid to intervenor were in fact reported on their return.
Respondent asserts, and petitioner does not dispute, that the
amounts listed in the notice as having been paid to petitioner
were not taken into account in the calculation of the deficiency.
These amounts are therefore not at issue. Because the $2,595
item, which was taken into account in the calculation, has been
conceded by respondent, the only adjustments remaining at issue
are the $14,399 and $805 items of unreported income paid to
intervenor. The accuracy-related penalty determined by
respondent was for a substantial understatement of income tax
under section 6662(d)(1).
After the issuance of the notice of deficiency, petitioner
submitted a Form 8857, Request for Innocent Spouse Relief, to the
Internal Revenue Service requesting relief pursuant to section
6015. Although no notice of determination appears in the record,
respondent states that relief has been denied under section
6015(b), (c), and (f).
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Last modified: May 25, 2011