Angela Rae Zachry, Petitioner, and Curtis Carlin, Intervenor - Page 4

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               During the latter part of 1996, intervenor received $68,648            
          in a distribution from Ms. Carlin’s section 401(k) retirement               
          account.  Intervenor also received proceeds from the sale of Ms.            
          Carlin’s home in Florida.                                                   
               Petitioner and intervenor filed their 1996 joint Federal tax           
          return timely.  On the return, they reported total income of                
          $42,926 but included only $5,220 in gross pension income and $220           
          in taxable pension income.  Respondent issued a Notice Proposing            
          Changes (CP-2000) on September 26, 1998, to petitioner and                  
          intervenor stating:  “information reported on their return did              
          not match what was reported by their employers, banks, and/or               
          other payers.”  Intervenor did not respond to this notice.  On              
          March 8, 1999, petitioner filed Form 8857, Request for Innocent             
          Spouse Relief.  It was subsequently denied.                                 
               On April 12, 2000, respondent issued a notice of deficiency            
          to petitioner and intervenor for their 1996 tax.  Respondent                
          determined petitioner and intervenor underreported the wages from           
          Show Tech Support, Inc., and pension income paid to intervenor              
          and failed to report nonemployee compensation paid to intervenor            
          from ACC Productions, Inc.  The entire deficiency was based on              
          the payments made to intervenor, as noted on the various Forms              
          1099.  A timely petition was filed in this Court in the names of            
          both intervenor and petitioner.  Because the petition was                   







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