- 2 - respondent sent petitioners a notice of deficiency, determining a $20,710 deficiency and a $4,142 section 6662(a)1 penalty. In response, on March 29, 1996, petitioners sent their petition to the Court and a second amended return relating to 1993 to the Internal Revenue Service. On April 2 and 3, 1996, respectively, the petition and the second amended return were filed. Petitioners, in the petition, disputed the entire amount of the deficiency and penalty as follows: The Commissioner has asserted deficiencies in income taxes and additions to taxes for the Petitioners taxable year 1993, all of which are in dispute, as follows: Deficiency: Increase in Tax $20,710 Penalties: Section 6662(a) $ 4,142 The petition also stated that “The Petitioners have correctly reported the sale of the business property on their amended 1993 individual income tax return, form 1040X”.2 On May 27, 1996, respondent made a $12,655 assessment for the amount shown as tax on petitioners’ second amended return and sent petitioners a notice and demand for payment. Respondent also sent petitioners an audit statement, determining a $2,931 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. Dollar amounts are generally rounded to the nearest dollar. 2 The petition refers to an “amended 1993 individual income tax return”. At the time they mailed the petition, petitioners had submitted two amended returns to the Internal Revenue Service. Thus, it is not clear whether petitioners are referring to the first or the second amended return.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011