- 3 - petitioner and defendants entered into a Confidential Settlement Agreement and General Release (settlement agreement) wherein petitioner would receive $75,000 for pain and suffering regarding the alleged claims. Petitioner received $75,000 in settlement proceeds from Woody’s Wharf in 1998. Woody’s Wharf issued a Form-1099 MISC, Miscellaneous Income, to petitioner and reported the payment to the Internal Revenue Service. II. Tax Return Petitioner timely filed a 1998 Federal income tax return reflecting a tax liability of $3,460. There was no remittance with the return. In March 2000, petitioner paid in full the outstanding tax liability, plus accruals of interest and an addition to tax for failure to timely pay the tax shown on the return. III. Adjustments and Notice of Deficiency On July 26, 2000, respondent issued a 30-day letter to petitioner proposing changes to her 1998 return, resulting in an additional tax liability due from petitioner of $25,466. Petitioner disagreed with the proposed changes. On December 6, 2000, respondent issued a notice of deficiency for 1998 determining a deficiency of $19,024, and an accuracy-related penalty under section 6662(a) of $3,805. Petitioner did not file a petition with this Court, but on December 12, 2000, petitioner’s counsel submitted a letter toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011