Susan F. Mostafa - Page 3

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          the first Star Bank IRA.  On April 30, 1996, petitioner made a              
          $7,000 contribution to the second Star Bank IRA.  On June 17,               
          1996, petitioner received a $7,010 distribution from the second             
          Star Bank IRA.  Petitioner did not have any tax withheld from the           
          IRA distributions.                                                          
               Petitioner did not file a Federal income tax return for                
          1996.  On February 8, 1999, petitioner attempted to file a return           
          for 1996 and elected married filing jointly status.  However,               
          respondent did not process the return because it was not signed             
          by petitioner’s husband.                                                    
               On April 26, 2004, respondent sent petitioner a notice of              
          deficiency covering her 1996 taxable year.  Using information               
          received from third parties, respondent determined that                     
          petitioner was required to include in gross income wages of                 
          $1,076 from the public school district and IRA distributions of             
          $14,010 from Star Bank.  Respondent allowed petitioner a personal           
          exemption of $2,550 and a standard deduction of $3,350, and                 
          determined a corresponding income tax deficiency of $1,377.                 
          Respondent also determined that petitioner was liable for                   
          additions to tax of $310 and $344 under section 6651(a)(1) and              
          (2), respectively.3                                                         
               On June 19, 2004, petitioner filed a petition with this                

               3  Respondent concedes petitioner is not liable for the sec.           
          6651(a)(2) addition to tax.  See supra note 2.                              

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