Gloria J. Spurlock - Page 3

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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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