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payer’s signature, and on which petitioner had made certain
entries and had written certain language, including the phrase
“Without Prejudice” that appeared above his signature on that
document. In petitioner’s document for 1996, petitioner showed
$9,237 of interest, $1,632 of dividend, $97,284 of capital gain,
$-803 with respect to rental real estate, and tax due of $25,624.
Petitioner did not include in petitioner’s document for 1996
Schedule C, Profit or Loss From Business (Schedule C), or any
other schedule showing receipts and expenses with respect to the
washing machine repair business that petitioner conducted during
1996.
Respondent did not file petitioner’s document for 1996 as
petitioner’s tax return for that year. Nor did respondent file a
tax return for petitioner for 1997.
Respondent issued to petitioner a notice for his taxable
years 1996 and 1997. In that notice, respondent determined,
inter alia, that petitioner had Schedule C net profit subject to
tax of $67,703 and $116,306 for 1996 and 1997, respectively.
Respondent further determined in the notice that during 1997
petitioner received pension income of $3,852 and that he is
liable for that year for the 10-percent additional tax under
section 72(t)(1) on that income (i.e., a 10-percent additional
tax under section 72(t)(1) of $385). Respondent also determined
in the notice that petitioner is liable for each of the years at
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Last modified: May 25, 2011