- 12 -
Petitioner admitted that she “didn’t know anything about
antique and estate jewelry as to value before [she] started the
business.” During taxable year 1999, petitioner purchased a
considerable number of books and periodicals to assist her in
learning the business of selling and repairing antique and estate
jewelry.
Additional Tax--Section 72(t)
During taxable year 1999, petitioner received a taxable
distribution from her 401(k) plan held by Putnam Investments of
$10,412. Petitioner was “nearing [her] 40th birthday” in 1999.
Audit Examination
Petitioner timely filed a Form 1040 for taxable year 1999.
Petitioner attached to her Form 1040 for taxable year 1999 a
“Special Handling” cover letter requesting a review of her
return. Respondent mailed petitioner a letter dated June 9,
2000, thanking her for her inquiry and stating that the IRS had
not “resolved the matter.” Petitioner received a letter dated
September 14, 2001, advising her that based upon review of third
party records, respondent proposed changes to her Form 1040 for
taxable year 1999. Petitioner never entered into a closing
agreement with the IRS with respect to taxable year 1999.
Petitioner never received a letter stating that the IRS had
accepted her 1999 tax return, nor had she received a letter
stating that her 1999 tax return had been audited as requested.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011