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return also included a Form 8275. The disclosure statement
cross-referenced the footnote in Statement 2.
On or about April 16, 1998, petitioner filed an amended 1996
Federal income tax return. On the amended return, among other
things, petitioner decreased his adjusted gross income by $1
million. Essentially, petitioner sought to exclude the November
1996 payment from income and sought a refund of Federal income
taxes paid with respect to the November 1996 payment.
Petitioner’s amended return also included a Form 8275. The
disclosure statement referred to an attached explanation. The
explanation was substantially similar to paragraphs 1 and 3 of
the footnote contained in his 1997 return. The explanation also
stated: “The taxpayer’s original 1996 Form 1040, however,
erroneously reported $1 million of the amounts received under the
settlement agreement as income. As a result, taxpayer is now
filing this amended return to correct the error in his original
return.”
Examination of Petitioner’s 1996, 1997, and 1998 Tax Returns
Revenue Agent Marcelle Colline (RA Colline) conducted the
examination of petitioner’s 1996, 1997, and 1998 returns. RA
Colline has worked at the Internal Revenue Service (IRS) for
approximately 20 years. During most of that time, she has been a
revenue agent. In 2001, she was promoted to manager.
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