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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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