- 2 - Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated by this reference. When she filed her petition, petitioner was a resident of Dallas, Texas. Background Respondent seeks to collect petitioner’s unpaid tax liabilities from taxable years 1996, 1997, 1998, 2000, and 2001, as follows: Year Deficiency Additions to Tax Accrued Interest 1996 $2,633.27 $526.86 $969.31 1997 3,751.69 786.38 1,086.20 1998 2,122.82 525.00 832.77 2000 230.90 43.78 34.38 2001 1,702.39 336.40 151.95 The amounts, set forth in the chart above, are from respondent’s MRFTA-Y transcript of account, dated April 2004, and reflect various adjustments, so they do not correspond exactly to deficiencies initially determined. Interest and additions to tax are accrued through April 2004. For taxable year 1996, petitioner received a statutory notice of deficiency and timely filed a petition with this Court. She signed a stipulation for decision on June 14, 1999, and agreed to a deficiency of $2,794. This Court’s decision with respect to her 1996 taxes was entered on June 14, 1999. For taxable year 1997, respondent issued to petitioner a statutory notice of deficiency in which respondent determined aPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011