Cheryl McKnight - Page 11

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          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                 
               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:                                                              

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Last modified: May 25, 2011