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C. Respondent’s Examination
Petitioner did not file Federal income tax returns for 1996-
98. Respondent began the examination of petitioner’s 1996-98 tax
years after July 22, 1998. On April 6, 2001, respondent mailed
notices of deficiency to petitioner in which respondent
determined deficiencies and additions to tax for petitioner’s
1996-98 tax years. Respondent’s determination was based on
information returns received from third-parties reporting that
the following payments had been made to petitioner during the
years in issue:
1996
Amount Payor Description
$39,000 Zelesky, Cornelius, Real estate sales
Hallmark, Roper
26 Zelesky, Cornelius, Buyer real estate
Hallmark, Roper tax
1 Everen Clearing Corp. Stocks/bonds sales
4 Everen Clearing Corp. Stocks/bonds sales
22,769 Regional Operations Stocks/bonds sales
Group
24,803 Regional Operations Stocks/bonds sales
Group
8 Income Fund of Dividends
America
8,214 Regional Operations Capital gains
Group
10,097 Regional Operations Dividends
Group
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Last modified: May 25, 2011