- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011