-3-
On or about April 15, 2001, petitioner filed a 2000 Federal
income tax return (2000 return) using the filing status of
“Single”. Petitioner’s 2000 return was prepared by a certified
public accountant named Gary Campbell (Campbell). Petitioner’s
2000 return reported that petitioner’s address was 4302 Callahan
and that his total income and taxable income were $6,524 and
zero, respectively. Petitioner’s 2000 return reported that
petitioner’s total income consisted of taxable interest of $939,
ordinary dividends of $103, business income of $93,886 (gross
income of $208,170 less total expenses of $114,284), a capital
loss of $3,000, taxable individual retirement account (IRA)
distributions of $3,527, and passthrough losses totaling $88,931.
Respondent processed petitioner’s 2000 return on July 23, 2001.
Respondent received certain information returns relating to
petitioner’s 2000 return. In relevant part, respondent received:
(1)A 2000 Form W-2, Wage and Tax Statement, reporting that
petitioner had received wages of $165,586 and (2)a 2000 Form
1099-S, Proceeds From Real Estate Transactions, reporting that
petitioner had received $525,000 from the sale of 4302 Callahan.
On October 25, 2002, respondent mailed to petitioner at 4302
Callahan a Letter 2201(DO) (examination notice) stating that
petitioner’s 2000 return had been selected for examination.2 The
2 More specifically, the letter was addressed to petitioner
and Davis (then known as Theresa L. Ricci), attention petitioner.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011