Gary R. Davis - Page 5

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          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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