- 3 - 1994 and 1995 Petitioner worked for the City and County of San Francisco (the city and county) for more than 30 years. During the taxable years 1994 and 1995, petitioner was an operator of light rail vehicles. Although petitioner earned wage income during both years, he failed to file his 1994 and 1995 Federal income tax returns.1 On December 11, 1997, respondent issued a notice of deficiency to petitioner for the taxable year 1995. Petitioner received the notice of deficiency but did not file a petition with the Court. A notice of deficiency for the taxable year 1994 was not made part of the record. 1996, 1997, and 1998 Petitioner was a member of a pension plan administered by the city and county (the plan). Before retiring, petitioner made after-tax contributions to the plan totaling $71,244.41. The city and county also contributed to the plan on petitioner’s behalf. Petitioner retired from the city and county in December 1995 at the age of 56. He began receiving distributions from the plan on February 1, 1996. Petitioner received gross distributions of $31,996.57, $34,714.88, and $35,756.37 for the taxable years 1 Respondent asserts he prepared a substitute for return for petitioner for each taxable year, see sec. 6020(b), but neither substitute for return was made part of the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011