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was born in 1993. Petitioner has custody of her daughter and has
struggled very hard to support herself and her daughter despite
difficult circumstances. During 1996, petitioner was a newspaper
carrier. Following her divorce from Mr. Magee, petitioner filed
for bankruptcy, but she has since then purchased a home. Other
than the fact that Mr. Magee failed to make court-ordered child
support payments, the record does not provide any specific
information regarding Mr. Magee or any information with respect
to the manner in which petitioner and Mr. Magee conducted their
financial affairs.
II. Procedural History
Petitioner and Mr. Magee filed a joint Form 1040, U.S.
Individual Income Tax Return, for the 1996 taxable year on July
26, 1998, prepared at the behest of Mr. Magee by a professional
tax return preparer. The tax return showed the following: Total
income of $38,177; tax of $4,474; tax paid of $2,469 (by Mr.
Magee’s withholdings); and a balance of tax due of $2,005. As
reported on Schedule C, Profit or Loss From Business Income, of
the joint tax return, petitioner grossed $11,032 from the
delivery of newspapers and claimed $7,376 in expenses. The
return was processed, and the tax shown due on the return was
assessed on August 24, 1998.
A notice and demand was mailed to petitioner on August 24,
1998, at petitioner’s last known address as listed on her 1996
return. Respondent transferred and applied petitioner’s tax
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