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On December 22, 2000, respondent issued notices of deficiency
based on the SFRs. In the notices of deficiency, respondent
determined that petitioner received unreported interest income in
the following amounts, on the basis of information reports from
financial institutions:5
Year Unreported Interest Income
1996 $32,668
1997 33,895
1998 32,678
On June 2, 2003, this case was called for trial in Lubbock,
Texas. Petitioner failed to appear, and no appearance was made
on his behalf.
Discussion
Although petitioner failed to appear at trial and to
prosecute his case, respondent’s counsel chose to proceed with
4(...continued)
unnecessary to decide whether the returns that respondent
prepared in this case meet the requirements of sec. 6020(b). For
convenience, we refer to these returns as SFRs. See Swanson v.
Commissioner, 121 T.C. 111, 112-113 n.1 (2003).
5 On Forms 1099-INT, Interest Income, the financial
institutions reported interest income paid to petitioner totaling
at least $32,668, $33,895, and $32,678 for 1996, 1997, and 1998,
respectively. Most if not all of these Forms 1099-INT listed
incorrect taxpayer identification numbers. Using an automated
system, the IRS matched the Forms 1099-INT to petitioner’s
correct taxpayer identification number.
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