- 3 - 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 wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011