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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
return.
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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