Teresa J. Fox - Page 3

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          assaulting petitioner.  Mr. Shattun filed for bankruptcy under              
          chapter 13 on a date not stated in the record and listed the tax            
          deficiency for 2000 as one of his debts.                                    
          B.   Petitioner and Mr. Shattun’s Tax Return for 2000 and                   
               Petitioner’s Tax Returns for 2002 and 2003                             
               Petitioner and Mr. Shattun worked together to prepare their            
          2000 joint Form 1040, U.S. Individual Income Tax Return, which              
          they filed on February 11, 2001.  They used a well-known brand of           
          tax preparation software.  They reported a distribution of                  
          $21,992 from Mr. Shattun’s section 401(k) retirement plan on line           
          16a of that return.  They reported a taxable amount of $2,199 on            
          line 16b.  Petitioner and Mr. Shattun signed the return                     
          electronically.                                                             
               Petitioner and Mr. Shattun reported a tax liability of                 
          $5,446 and payments of $11,285, and requested a refund of $5,839.           
          Respondent determined a deficiency of $6,884 for petitioner and             
          Mr. Shattun resulting from the section 401(k) retirement plan               
          distribution.  Respondent also determined that petitioner and Mr.           
          Shattun are liable for an accuracy-related penalty of $1,377.  If           
          petitioner does not qualify for relief under section 6015(f), she           
          will remain liable for tax and penalties totaling $8,261 and                
          related interest.                                                           
               Petitioner filed her 2002 and 2003 Federal income tax                  
          returns untimely in August or September 2004.  She did not timely           
          pay tax totaling about $5,000 for those years.  Petitioner agreed           





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