- 11 - petitioner and to John a notice of deficiency. In the notice of deficiency, respondent disallowed $19,721 in mortgage interest deductions, charged petitioner and John with self-employment taxes on the MGI income, and determined a tax deficiency against petitioner and John of $6,452 (the deficiency). Respondent also determined that petitioner and John were liable for a $1,290 accuracy-related penalty. Respondent mailed the above notice of deficiency to John’s separate address. John did not inform petitioner that he had received the notice of deficiency. Neither petitioner nor John filed with this Court a petition for redetermination of the deficiency. Petitioner did not learn of the notice of deficiency until after respondent had assessed the deficiency. In further payment of the balance due on the underpayment, the deficiency, the related penalty, and the additions to tax (that were later assessed) and interest, respondent offset and applied Federal income tax refunds that were due to petitioner for 1999 through 2002, and petitioner individually made a number of additional $938 installment payments to respondent. Also, John’s estate made a $12,663 payment. The below schedule summarizes the various payments made jointly by petitioner and John, as well as the separate payments made by petitioner and by John’s Estate:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011