Anna E. Charlton - Page 2

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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                                          
               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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