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child and four other minor children. Petitioner resumed her
teaching around December of 2001.
Intervenor has taken a few college courses and has received
some technical training. During 2000, he was employed by
Southwest Computer Services.
On Form 1040, U.S. Individual Income Tax Return, for 2000,
petitioner and intervenor reported adjusted gross income of
$90,018 and taxable pensions and annuities of $2,919. Using
third party information returns, respondent determined that
taxable interest of $5 and an additional taxable pension
distribution of $19,692, received by intervenor in 2000
(collectively, the omitted income), were not reported on the
return.
On November 25, 2002, respondent issued to petitioner and
intervenor a statutory notice of deficiency for 2000. Neither
petitioner nor intervenor petitioned this Court in response to
the notice of deficiency. Accordingly, a deficiency of $7,777
and a section 6662(a) accuracy-related penalty of $1,162 were
assessed against petitioner and intervenor.
On March 22, 2003, respondent received a Form 1040X, Amended
U.S. Individual Income Tax Return, for 2000, signed only by
intervenor. The amended return included income items that were
not accounted for in the notice of deficiency, resulting in an
additional assessment of $19,937.
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