Diana Cote - Page 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,               

Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011