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that opinion, we decided that tax liabilities shown on what
petitioner claimed were section 6020(b)1 returns did not affect
whether there was a “deficiency” under section 6211(a) and that
any amounts shown thereon were subject to the deficiency
procedures. The issues for decision are: (1) Whether petitioner
received unreported income in the form of wages, nonemployee
compensation, and distributions from individual retirement plans;
(2) whether petitioner is liable for additions to tax under
sections 6651(a)(1) and (2) and 6654.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibit are
incorporated herein by this reference. At the time of filing the
petition, petitioner resided in Louisville, Kentucky.
Petitioner did not file Federal income tax returns for her
1995, 1996, and 1997 tax years. Respondent commenced an
examination of petitioner’s 1995, 1996, and 1997 tax years at
some point after July 22, 1998. On February 20, 2001, respondent
issued a notice of deficiency to petitioner in which he
determined: (1) Petitioner received nonemployee compensation of
$7,515 in 1995 and $20,542 in 1996 from Ursuline Campus Schools,
Inc. (Ursuline); (2) she received wages of $7,347 in 1995 and
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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