Theodore W. Banis, Jr. - Page 4

                                        - 4 -                                         
          with his return.  Transcripts1 of petitioner’s account for 1996             
          show that, on August 11, 1997, respondent assessed a tax                    
          liability of $12,245, gave a credit for the $2,726 of withheld              
          taxes, assessed an addition to tax for failure to pay of $190,              
          and assessed interest of $281.  The total assessment of $9,990              
          was listed as the “Assessed Balance” for 1996 in the notice of              
          levy covering that year.                                                    
               In a notice of proposed changes (Form CP 2000) dated March             
          11, 1998, (the CP 2000 letter), respondent’s Philadelphia Service           
          Center advised petitioner of proposed changes to petitioner’s               
          1996 return that would result in additional tax, penalty, and               
          interest due in the sum of $11,482.  The proposed changes                   
          consisted of (1) a $24,912 net increase in taxable income:                  
          $25,496 of “nonemployee compensation” reported on Form 1099-MISC,           
          Miscellaneous Income, ($25,336 reported by Nationwide Life                  
          Insurance Co. (Nationwide) and $160 by Ford Motor Credit) less a            
          $584 deduction for 50 percent of a proposed self-employment tax,            
          (2) self-employment tax, (3) an accuracy related penalty, and (4)           
          interest from April 15, 1997 to March 26, 1998.                             



               1  Each of the transcripts in evidence is derived from                 
          current account information in respondent’s master file.  In                
          general, transcripts are obtained by entering various command               
          codes (e.g., MFTRA, TXMODA) into respondent’s integrated data               
          retrieval system (IDRS) in order to obtain a particular                     
          transcript.  IDRS is essentially the interface between                      
          respondent’s employees and respondent’s various computer systems.           
          See Crow v. Commissioner, T.C. Memo. 2002-149 n.6.                          




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011