Janet L. Pickering - Page 5

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               During the 2000 taxable year, petitioner also sold 769                 
          shares of stock in Peco Energy Co. (Peco stock) and received sale           
          proceeds of $31,581 through the following transactions:4                    
               No. of    Date of   Sales     Date of     Purchase                     
               Shares     Sale      Proceeds    Purchase      Price                   
               50     02/09/00     $2,045.18    01/10/95    $1,231.25                 
              180     02/15/00    7,177.03    01/10/95   4,432.50                    
               50     04/24/00     2,017.47    01/10/95   1,231.25                    
               50     05/22/00     2,183.76    01/10/95   1,231.25                    
               295     06/20/00    12,202.53    01/10/95    7,264.38                  
               13     06/20/00     537.73    06/30/95     354.10                      
               12     06/20/00     496.37    09/29/95       359.20                    
               13     06/20/00     537.74    12/20/95     391.21                      
               15     06/20/00     620.46    03/29/96     396.91                      
               15     06/20/00     620.47    06/28/96     403.35                      
               17     06/20/00     703.20    09/30/96     410.09                      
               17     06/20/00     703.20    12/20/96     431.81                      
               21     06/20/00     868.66    03/31/97     439.59                      
               21     06/20/00     868.66    06/30/97     449.24                      
          The sale of Peco stock resulted in a gain of $12,554.87.                    
               Petitioner made estimated tax payments of $254 for the 2000            
          taxable year.  In addition, petitioner requested, and respondent            
          granted, two extensions of time to file a tax return for the 2000           
          taxable year.  Despite these extensions, petitioner did not file            
          a return for the 2000 taxable year.                                         
               As we indicated earlier, respondent determined that                    
          petitioner received unreported income and that she is liable for            
          certain additions to tax for the 2000 taxable year.  Respondent             


               4  While the parties stipulated that petitioner received               
          sale proceeds of $31,581, petitioner’s annual statement from                
          Merrill Lynch indicates that she received proceeds of $31,582.46.           
          This difference is immaterial, and we accept the stipulated                 
          amount.                                                                     




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