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Background
At the time he filed the petition, petitioner resided in
Delray, Florida.
Petitioner, an attorney, received his law degree from
Georgetown University Law School in 1958 and was admitted to
practice law in the State of New York in 1959. He is admitted to
practice before the United States Tax Court.
Throughout 2000, petitioner was married.
The Nov. 10 Return
The Nov. 10 return, which, as previously stated, was
received by respondent on November 10, 2003, purports to be a
joint income tax return for petitioner and his wife for the 2000
taxable (calendar) year (2000). Respondent had not previously
received a return from petitioner for 2000, and, on December 4,
2002, respondent had prepared a substitute 2000 return for
petitioner pursuant to section 6020(b). On November 10, 2003,
respondent filed the Nov. 10 return as an amended return.
Petitioner did not mail the Nov. 10 return to respondent earlier
than November 2003.
Gross Income and Schedule D Proceeds
The parties have stipulated that, in 2000, petitioner
received taxable wages, Social Security payments, pension
payments, interest, and dividends of $29,327, $14,099, $15,884,
$4,482, and $6,238, respectively.
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Last modified: May 25, 2011