Darlene R. Esposito, a.k.a. Amnesty National - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time petitioner filed the petition, she resided in              
          Rahway, New Jersey.                                                         
               Petitioner timely filed Form 1040, U.S. Individual Income              
          Tax Return, for her taxable year 1999 (1999 return).  In peti-              
          tioner’s 1999 return, petitioner reported taxable income of                 
          $744.67, total tax of $288.66, tax withheld of $2,734, and other            
          tax payments (other tax payments) of $6,000 and claimed an                  
          overpayment and refund of $8,445.34.                                        
               In support of the other tax payments of $6,000 reported in             
          her 1999 return, petitioner attached two Forms 2439, Notice to              
          Shareholder of Undistributed Long-Term Capital Gains (Form 2439),           
          that she prepared.  Form 2439 is a form that the Internal Revenue           
          Service (Service) requires a regulated investment company (RIC)             
          or a real estate investment trust (REIT) to file with the Service           
          and to send to its shareholders with respect to its undistributed           
          long-term capital gains.                                                    
               The respective Forms 2439 that petitioner prepared and that            
          she attached to her 1999 return showed, inter alia, the following           
          information:                                                                











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