-3-
Union, interest of $116 from the Xerox Federal Credit Union,
distributions from an IRA of $179,558 from OppenheimerFunds
Services, distributions from an IRA of $3,407 from Delaware
Service Company, and distributions from an IRA of $129,064 from
Franklin Templeton Investor Services. Petitioner’s basis in the
securities sold through OppenheimerFunds Services was $100,000.
During 1999, petitioner was under the age of 55, and she did not
receive the distributions from any of her IRAs as a result of
becoming disabled. Federal income tax of $55,000 was withheld
from her income for 1999.
Petitioner did not file a Federal income tax return for
1999. Respondent has no record that petitioner filed a tax
return for 1999, and petitioner has never disputed respondent’s
assertion that petitioner failed to file a tax return for 1999.
Respondent issued a notice of deficiency on April 7, 2004, and
determined the above-stated deficiency and additions to tax.
Petitioner timely filed a petition disputing the determinations.2
Petitioner failed to submit to the Court a pretrial
memorandum as required by the Court’s standing pretrial order.
2 On July 12, 2004, the Court filed as a petition a letter
received from petitioner. By an order dated July 19, 2004, the
Court directed petitioner to file an amended petition complying
with the Rules of the Court as to form and content of a proper
petition by Sept. 2, 2004. Despite issuance by the Court of
several orders to petitioner in the ensuing months, petitioner
did not submit an amended petition to the Court until May 24,
2005.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011