- 9 - his supervisor. On May 29, 2002, the IRS issued to petitioner a statutory notice of deficiency for 1995 and 1996. In response, petitioner filed a petition with the Court on September 3, 2002, at docket No. 14104-02. On December 3, 2003, pursuant to a stipulation of the parties, this Court entered a decision in that case that petitioner owed a deficiency and addition to tax and penalty under sections 6651(a)(1) and 6662(a) for 1995 and a deficiency and an addition to tax under section 6651(a)(1) for 1996. Years in Issue: 1997, 1998, 1999, and 2000 Petitioner had gross receipts from consulting for the years 1997, 1998, 1999, and 2000 of $76,090, $178,747, $303,225, and $198,990, respectively. On August 21, 2003, when respondent issued petitioner a statutory notice of deficiency for each of these years, petitioner had not yet filed a Federal income tax return for any of them. Petitioner filed a timely petition on November 24, 2003, and thereafter provided Forms 1040 for 1997 through 2000 to respondent in March and April, 2004. The Forms 1040 reported less tax due than had been determined by the notice of deficiency. Following prolonged negotiation and petitioner’s presentation of additional evidence and substantiation in support of his reporting positions, the parties agreed to the following: The 1997 deficiency of $28,074 was reduced to $14,062; the 1998 deficiency of $66,821 wasPage: 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