James Curtis Barrett - Page 4

                                        - 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               
               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                
               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.                  

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