- 6 - 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 actionPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011