Shuang-Di Sun Bennett - Page 5

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          reporting that petitioner was paid wages of $19,384.68 in 1998.2            
          Petitioner failed to pay the amount of tax reported on her 1998             
               Petitioner’s 1998 return was prepared by a professional tax            
          preparer on October 20, 1999, and petitioner purportedly signed             
          and dated it on October 21, 1999.  However, her return was not              
          filed until December 13, 2000, a date occurring after petitioner            
          and Mr. Bennett were divorced.  She had not previously filed an             
          application for an extension of time to file a return.                      
          Respondent accepted petitioner’s return as it was filed and                 
          assessed the income tax liability reported therein as well as an            
          addition to tax for filing a delinquent return, an addition to              
          tax for failing to pay a tax shown on a return, and interest.               
          Respondent did not issue petitioner a statutory notice of                   
          deficiency for 1998.  Although petitioner was a married                     
          individual living in a community property State and filed a                 
          return as “married filing separately”, respondent did not                   
          determine or assess a tax based upon her one-half share of                  
          community income.                                                           
               On his separate 1998 return, also filed on December 13,                
          2000, Mr. Bennett reported gross income of $57,138, taxable                 
          income of $50,534, and a total tax due of $11,394.  Mr. Bennett’s           

               2  Other third-party information reported that petitioner              
          earned wages of $13,626 in 1998.                                            

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