- 2 -
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Capitola, California.
Petitioner filed two extensions of time to file his 1996
return, and respondent granted extensions of time to file his
1996 return to August 15 and October 15, 1997. On November 23,
1998, respondent filed a substitute return for petitioner for
1996. Petitioner’s transcript of account reflects that
petitioner filed a 1996 return on March 24, 1999.
Petitioner timely filed his 1998 return. Petitioner listed
a total tax and an amount owed of $508. Petitioner signed his
1998 return on March 15, 1999.
On August 23, 1999, respondent assessed for 1996 taxes of
$6,620, a late filing penalty of $1,407.15, an estimated tax
penalty of $330.71, a failure to pay tax penalty of $865.36, and
interest of $1,517.79.
On April 15, 2001, petitioner signed a Form 1040, U.S.
Individual Income Tax Return, for 1996. Petitioner submitted the
Form 1040 for 1996 in 2001 and listed a total tax of $4,471. The
Form 1040 for 1996 submitted in 2001 bears a received stamp dated
April 21, 2001.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011