-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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011