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third-party payor statements. The third-party payor statements
reflect the pension distributions and interest income outlined
above. However, the statement from the Social Security
Administration indicates that petitioner received $14,538 instead
of $13,876. On November 3, 2003, respondent prepared a
substitute for return for petitioner.
Respondent sent petitioner a notice of deficiency on April
19, 2004. As reflected in the notice, respondent determined that
petitioner received total income of $80,832 during 2000.3
Allowing petitioner a personal exemption of $2,800 and a standard
deduction of $5,500, respondent determined that petitioner had
taxable income of $72,532 and an outstanding Federal income tax
liability of $17,165. Further, respondent determined that
petitioner was liable for additions to tax of $3,862, $2,661, and
$923 under sections 6651(a)(1) and (2) and 6654, respectively.
Because respondent conceded that petitioner is not liable for the
section 6651(a)(2) addition to tax, respondent increased the
section 6651(a)(1) addition to tax to $4,291.
In response to the notice of deficiency, petitioner filed a
petition with this Court on July 15, 2004.
3 This figure does not take into account respondent’s
concessions See supra note 2.
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