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wish us to consider”. Petitioner, in a letter dated May 9, 2004,
disagreed with respondent’s proposed changes and stated that the
income was properly “accounted for in * * * [his] 2002 Tax
Return”. Petitioner, however, did admit that he failed to
account for capital gain income relating to the sale of three
mutual funds and concluded that his refund of $1,287 should have
been $1,179 (i.e., a difference of $108). Petitioner enclosed a
check for $108 but did not attach any supporting documentation.
By notice of deficiency dated September 7, 2004, respondent
determined a deficiency of $18,402 and a section 6662 accuracy-
related penalty of $3,680 relating to petitioner’s 2002 return.
On December 7, 2004, petitioner, while residing in Lake Forest,
California, filed his petition with this Court.
In November of 2004, petitioner contacted Heather Smith of
the Taxpayer Advocate Service. In a letter dated January 10,
2005, Ms. Smith concluded that petitioner, on his 2002 return,
had failed to report dividend income and a “considerable amount
of stocks and bonds income”. On January 24, 2005, the Court
filed respondent’s answer. That same day, petitioner, in
response to Ms. Smith’s January 10 letter, sent Ms. Smith a
corrected Schedule D, Capital Gains and Losses, and
substantiation of his tuition expense. On March 10, 2005, Ms.
Smith forwarded this documentation to respondent’s Appeals
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Last modified: May 25, 2011