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section 6651(a)(1)1 of $6,208,944, and an addition to tax for
failure to pay estimated tax under section 6654 of $922,946 for
petitioner's 2002 taxable year. In that notice, respondent also
determined that petitioner is liable for the addition to tax
under section 6651(a)(2) for failure to pay timely in an amount
to be calculated at a later date.2
Background
On May 1, 2006, petitioner commenced the present case by
filing a timely petition contesting respondent's determinations
set forth in the notice of deficiency. The petition alleges that
respondent erred in computing petitioner's taxable gain from
certain stock sales during 2002 by failing to subtract
petitioner's bases in those stocks from the sale proceeds. The
petition also alleges that petitioner filed a joint 2002 Federal
income tax return with her husband, Gary L. Francione, although
respondent has no record of receiving any return from petitioner
for 2002. Petitioner resided in Newton Square, Pennsylvania at
the time the petition was filed.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986 as in effect for the taxable
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
2 Respondent has since conceded (by amended answer,
discussed infra) petitioner's liability for the addition to tax
under sec. 6651(a)(2).
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Last modified: November 10, 2007