Mark Fowler and Joylyn Souter-Fowler - Page 3

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                                  FINDINGS OF FACT2                                   
               Petitioners resided in Garden Grove, California, when the              
          petition in this case was filed.                                            
          Separate Liabilities                                                        
               Petitioner filed his 1990 Federal income tax return late on            
          September 6, 1991.  On July 21, 1993, respondent mailed a                   
          statutory notice of deficiency to petitioner for his 1990 taxable           
          year.  Petitioner did not petition this Court to dispute the                
          deficiency.  On December 20, 1993, respondent assessed the $399             
          income tax deficiency and a $98.74 late-filing penalty under                
          section 6651(a)(1).  In addition, $104.40 of interest was                   
          assessed.  Petitioner does not contest the 1990 tax liability.              
               Petitioner timely filed his 1991 Federal income tax return             
          that contained several mathematical errors.  Respondent corrected           
          the mathematical errors in accord with section 6213(b)(1), and              
          assessments were made to correct the errors.  Respondent                    
          subsequently selected petitioner’s 1991 return for an audit                 
          examination.  On April 5, 1994, respondent mailed petitioner a              
          statutory notice of deficiency for his 1991 taxable year                    
          determining a $545 income tax deficiency.  Petitioner did not               
          petition this Court with respect to the 1991 notice of                      

               2 The parties’ stipulation of facts is incorporated by this            

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