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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
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:
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Last modified: May 25, 2011