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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 a
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