Roger L. Sherer - Page 6

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          petitioner for the year 1999 from Bear, Stearns Securities Corp.            
          (Bear Stearns) and a two-page summary in which he reported his              
          cost bases in the stocks and bonds sold during 1999, with the               
          exception of securities in the Bidwell Co. (Bidwell) described in           
          the Form 1099-MISC.  The Bear Stearns information petitioner                
          presented showed cost bases for those securities purchased in               
          1999.  Petitioner also claimed a $21,228 mortgage interest                  
          expense for the taxable year 1999 in his letter.  This expense              
          was supported by third-party documentation.  Respondent did not             
          allow this mortgage interest expense in preparing the substitute            
          for return for 1999.  In a reply letter dated June 14, 2004, the            
          Appeals officer advised petitioner to file an income tax return             
          for the taxable year 1999 in order to obtain credit for the cost            
          bases he reported in his summary and for the mortgage interest              
          expense he claimed.  Also in the letter of June 14, 2004, the               
          Appeals officer advised petitioner that she would be issuing a              
          notice of determination, sustaining respondent’s proposed lien              
          collection action, should petitioner fail to file an income tax             
          return for the year 1999 by June 18, 2004.  Petitioner received             
          the June 14, 2004, letter.  Petitioner did not file an income tax           
          return for 1999.  On July 9, 2004, the Appeals officer attempted            
          to contact petitioner via telephone.  Petitioner did not respond.           
               The Appeals officer issued a notice of determination to                
          petitioner on August 4, 2004, sustaining the proposed lien action           






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