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The issues for decision are: (1) Whether petitioner
received $15,800 of unreported income in 1996 as respondent
determined; and (2) whether petitioner is liable for additions to
tax under sections 6651(a)(1) and 6654.
FINDINGS OF FACT
Petitioner resided in La Habra, California, when she filed
the petition.
Petitioner failed to file a Federal income tax return and
failed to pay Federal income taxes for the 1996 tax year. On the
basis of third-party information, on April 28, 2004, respondent
issued a notice of deficiency to petitioner for the 1996 tax year
setting forth unreported non-employee income of $15,800.
Petitioner timely filed a petition with the Court on July
29, 2004, disputing that she received unreported nonemployee
income in 1996. Trial was held on this matter on March 17, 2005.
Although petitioner did not appear, her counsel did.
Petitioner’s counsel did not introduce witnesses nor provide
documentary evidence to support petitioner’s position. However,
petitioner’s counsel did cross-examine respondent’s sole witness.
During trial, respondent called one witness, Pam Wong, a tax
compliance officer employed by respondent. Ms. Wong’s testimony
was based solely upon her memory of reviewing petitioner’s
1(...continued)
the Internal Revenue Code, as amended. Amounts are rounded to
the nearest dollar.
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