- 3 -
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Elk Grove,
California.
Petitioner failed to timely file a Federal income tax return
for tax year 1999. Respondent determined petitioner’s income on
the basis of information returns submitted to respondent by third
party payors. Respondent also determined that petitioner is
liable for additions to tax.
1. Procedural History
After respondent issued petitioner a statutory notice of
deficiency, petitioner submitted a tax return for 1999 reflecting
most, but not all, of the unreported income determined in the
notice of deficiency. Petitioner also claimed deductions for
capital loss carryforwards and rental expenses. Respondent has
not processed this tax return, and no tax has been assessed as a
result of petitioner’s submitting the tax return.
Petitioner submitted to the Court a letter challenging the
notice of deficiency, and the Court filed it as petitioner’s
imperfect petition. Because the letter did not comply fully with
the requirements of Rule 34, by order the Court directed
petitioner to file a proper amended petition.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011