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On March 23, 2005, respondent filed a substitute for return
for petitioner and on April 11, 2005, assessed the tax shown
thereon. On May 8, 2006, petitioner filed his Form 1040, U.S.
Individual Income Tax Return, for 2002 (2002 return), in which he
failed to report receiving the $12,000 from Amex and the $1,830
from National. Respondent treated the 2002 return as an amended
return.
On May 9, 2006, respondent mailed petitioner a notice of
deficiency for 2002. The notice of deficiency was mailed before
respondent could take into consideration petitioner’s 2002
return. Using third-party payor information, respondent
determined petitioner owed $6,480 in Federal income tax on the
basis of: (1) Wage income of $21,816 from the Xerox Corporation,
$409 from Labor Ready Midwest, Inc., and $759 from the Doherty
Employment Group; (2) a taxable distribution of $1,830 from
National; and (3) other income of $12,000 from Amex. In the
notice of deficiency, respondent calculated tax using married
filing separately rates and allowed a standard deduction, one
personal exemption, a self-employment tax deduction of $848, and
an adjustment to prepayment credit of $1,669.
Petitioner filed an amended petition with the Court on
September 11, 2006.4
4 Petitioner’s original petition was timely filed with the
Court on July 19, 2006.
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Last modified: March 27, 2008