- 3 - In 1996 and 1997, the insurers paid $9,719 and $9,631, respectively, to the credit card companies on Hong’s behalf. For 1996 and 1997, petitioner prepared her and Hong’s joint Federal income tax returns. On their tax returns, petitioner and Hong, apparently under the impression that these amounts did not constitute taxable income, did not report the above insurance payments that had been made on Hong’s behalf. Upon audit for 1996 and 1997, respondent determined that the insurance payments constituted taxable income. In connection with respondent’s audit, Hong explained to petitioner that respondent’s adjustments were related to the taxability of the insurance payments made on his behalf. On December 15, 1998, and October 13, 1999, respectively, respondent’s notices of deficiency relating to petitioner and Hong’s 1996 and 1997 joint Federal income tax returns were mailed to petitioner and Hong. With regard to the notice of deficiency for each year, petitioner and Hong jointly filed petitions with the Tax Court to redetermine the deficiencies, and petitioner read and signed both petitions. The two cases were consolidated for trial. Prior to the trial, petitioner and Hong attended meetings with respondent’s Appeals Office and meetings with counsel for respondent. Petitioner spoke and participated in these meetings, and petitioner signed various documents including a stipulationPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011