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incorporated herein by this reference.2 At the time the petition
was filed, petitioner resided in Sterling, Virginia.
During the 2000 taxable year, petitioner received the
following: (1) Wages of $1,972 from the Loudon Baptist Temple;
(2) interest of $1,643 from both Merrill Lynch Pierce Fenner &
Smith (Merrill Lynch) and Prudential Securities, Inc.
(Prudential); (3) dividends of $1,561 from Merrill Lynch and
Prudential;3 and (4) an income tax refund of $114 from the
Commonwealth of Virginia Department of Tax.
On March 9, 2000, petitioner sold 125 shares of Series A,
8.5 percent cumulative preferred stock in Americo (Americo stock)
and received sale proceeds of $2,963. In January 1994,
petitioner had purchased 560 shares of Americo stock for
$13,864.50. The sale of Americo stock thus resulted in a loss of
$131.75.
2 The stipulation of facts was filed without trial and
without an appearance by petitioner at a trial scheduled for May
12, 2004. By Order dated May 12, 2004, we offered petitioner an
opportunity, if she so desired, to supplement the record by June
11, 2004. During a conference call with the parties on June 22,
2004, we again advised petitioner of an opportunity to supplement
the record. Other than the stipulation of facts and the attached
exhibits, the Court has not received any indication from
petitioner of an intention to supplement the record.
3 As indicated earlier, respondent concedes that petitioner
did not receive $347 in dividends, the difference between what
respondent determined in the notice of deficiency and the
stipulated amount of $721.
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