- 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