Bill Max Overton - Page 4

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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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