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For 1996, petitioner and her spouse filed a joint Federal
income tax return claiming an overpayment of $2,831, consisting
of $1,595 in withholdings and a $1,236 earned income credit.
That return, however, failed to include as income nonemployee
compensation of $4,469 earned by Mr. Murray and taxable wages of
$25 earned by petitioner. A notice of deficiency for the taxable
year 1996 was thereafter issued to petitioner and her spouse that
adjusted their income to include the omitted income. This
adjustment also caused a reduction of the earned income credit in
the amount of $884 due to the income limitations of section
32(a)(2).
Petitioner responded to the notice of deficiency for taxable
year 1995 with a handwritten note to the IRS; however, no
petition was filed in this Court with respect to either statutory
notice. The assessments for taxable years 1995 and 1996 were
made on February 23, 1998, and April 12, 1999, respectively. No
payments were made on the 1995 and 1996 deficiencies.
Petitioner sustained a work-related injury on June 1, 1995.
While petitioner was receiving treatment for the injury, her
husband was transferred to Colorado in August 2005 for work.
Petitioner remained in Florida awaiting surgery and did not
relocate to Colorado until sometime in October.
Petitioner and her spouse did not have joint or separate
bank accounts; they paid their bills in cash or money orders.
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