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1997. Petitioner filed Federal income tax returns, Forms 1120,
U.S. Corporation Income Tax Return, for 1993, 1994, and 1995 on
February 5, 1997, and for 1996 on May 7, 1997.
The due date for filing Form 1096, Annual Summary and
Transmittal of U.S. Information Returns, together with Forms
1099, for 1996 was February 28, 1997. Petitioner did not request
an extension of time within which to file its Form 1096 for 1996.
Chris Ihejirika, petitioner’s accountant from 1991 through early
1997, prepared Forms 1099-MISC, Miscellaneous Income, for
petitioner’s workers. Petitioner determined that some of the
Forms 1099-MISC prepared by Mr. Ihejirika were incorrect, and it
prepared corrected Forms 1099-MISC. Petitioner mailed corrected
Forms 1099-MISC to each of the reclassified physicians during the
period from January 21 through March 5, 1997. After February 28,
1997, petitioner mailed only one corrected Form 1099-MISC to an
individual physician.
On May 20, 1997, petitioner mailed two Forms 1096, together
with Forms 1099-MISC, to respondent by cover letter dated May 16,
1997. Respondent has no record of receiving the Forms 1096 and
1099-MISC sent by petitioner on May 20, 1997. Sometime after
December 22, 1998, petitioner filed Form 1096, together with 46
Forms 1099-MISC, for 1996.
On or about March 4, 1998, respondent began an examination
of petitioner’s 1996 income tax liability. In December 1998,
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