Christina L. Belmont - Page 3




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          has not filed a Federal income tax return for any tax year after            
          1999 through the date of trial.  She has paid no Federal income             
          tax for 2001.  In August 2003, she wrote a letter to the                    
          Department of the Treasury which stated that she was not required           
          to keep books and records and asked the Department of the                   
          Treasury to cite any statute which made her liable to pay Federal           
          income tax.  She did not receive a response.                                
               On May 28, 2004, respondent mailed a notice of deficiency to           
          petitioner for 2001.  The notice of deficiency correctly                    
          identified petitioner’s address and Social Security number.  The            
          notice of deficiency identified petitioner as Christina L. Gore,            
          rather than Christina L. Belmont, the name she currently uses.4             
               Respondent determined, using third-party payor information,            
          that petitioner owed $4,333 in Federal income tax on the basis of           
          wage income of $5,924 received from Famiano and distributions of            
          $18,239 received from a Fidelity IRA.  In the notice of                     
          deficiency, respondent also determined additional tax of 10                 
          percent for early distributions from a retirement plan pursuant             
          to section 72(t), allowed a standard deduction, allowed one                 
          personal exemption, calculated tax using single individual rates,           
          and asserted additions to tax pursuant to sections 6651(a)(1) and           
          6654 of $975 and $171, respectively.                                        



               4 Petitioner used the name Gore before she was divorced in             
          1980.                                                                       





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