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additions to tax for petitioner’s 1998, 1999, 2000, and 2001
taxable years:
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1998 $2,283.60 $1,070.93 $103.64
1999 5,634.00 2,422.62 270.56
2000 4,267.00 1,542.90 229.49
2001 2,621.00 812.51 103.72
The issues for decision are whether petitioner received
taxable income during those years, and, if so, whether she is
liable for the tax and additions to tax determined by respondent
for such years.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner’s
legal residence was Lake City, Georgia.
Petitioner did not file Federal income tax returns for any
of the years at issue. She did not file for extensions of time
to file for those years, nor did she make any estimated payments
toward her tax liabilities. Respondent prepared substitutes for
return for each of the subject years and issued a notice of
deficiency for each year based on wage and dividend information
reported by six different third party payers. The third party
payers who reported paying petitioner wages or dividends were
Minolta Business Systems, Inc. (Minolta); Ikon Office Solutions
West, Inc. (Ikon); PFS Shareholder Services S B Money Fund; OCE
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Last modified: May 25, 2011