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Petitioner prepared the joint Federal income tax return for 1999
for Jorgensen and herself. After the return was signed but prior
to its filing, Jorgensen informed petitioner that the return was
“missing something”. In a letter to respondent dated May 21,
2002, petitioner stated that her husband advised her that an
employer-supplied document was missing from the return; no copy
was available, “so the return was mailed as it was.” As she
discovered later, missing from the return was income paid to
Jorgensen that was reported on “Form 1099”. Petitioners did not
file an amended return to report the omitted income.
Petitioner and Jorgensen were divorced on February 13, 2001.
Under the “Agreed Final Decree of Divorce”, Jorgensen is required
to pay child support and any indebtedness due the Internal
Revenue Service for their Federal income taxes for tax years
during their marriage ending with calendar year 2000. Neither of
these obligations has been satisfied.
On August 15, 2001, respondent sent to petitioner and
Jorgensen a statutory notice of deficiency for 1999. The notice
determined that the joint return filed by petitioner and
Jorgensen failed to report nonemployee compensation of $16,638
which (after a deduction for self-employment tax) resulted in an
income tax deficiency of $5,206. No petition for redetermination
of the deficiency was filed with the Court by petitioner or
Jorgensen.
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Last modified: May 25, 2011