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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.
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