-5-
2000 return and detected that respondent had not received
petitioner’s agreement to the proposed changes. The Letter
1912(DO) stated that petitioner should contact the representative
designated on the letter within 10 days or that a notice of
deficiency would be issued to petitioner for 2000. The Letter
1912(DO) referenced and was accompanied by a publication that
discussed the examination process and petitioner’s appeal rights.
On November 14, 2003, after not having received a response from
petitioner as to the Letter 1912(DO), respondent’s district
office closed petitioner’s case and recommended that a notice of
deficiency be issued to petitioner for 2000.
Respondent received petitioner’s timely filed (pursuant to
extensions) joint 2002 Federal income tax return (2002 return) on
October 19, 2003, and processed it on November 24, 2003.
Petitioner’s 2002 return reported that petitioner’s address was
in Las Vegas at 912 Sir James Bridge Way (912 Sir James Bridge).
Petitioner had purchased 912 Sir James Bridge on April 7, 2003.
Petitioner had sold 629 Mariola on April 18, 2003.
On January 15, 2004, respondent mailed a notice of
deficiency for 2000 to petitioner at 912 Sir James Bridge. This
notice determined an income tax deficiency of $107,844 and a
section 6662(a) accuracy-related penalty of $19,740.60. For the
most part, respondent determined in the notice that petitioner
was taxable on the sales proceeds reported on Form 1099-S and was
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Last modified: May 25, 2011