- 5 -
a total of $21,267 as “Gross proceeds” ($21,267 of gross pro-
ceeds) from broker transactions described as “EMP PLN SHRS SOLD”.
Petitioners timely filed a petition with the Court with
respect to the 2002 notice. In the petition, petitioners alleged
in pertinent part: “The petitioners disagree with IRS in the
determination of the deficiency because it was based on the
insufficient and inaccurate information.”
On September 16, 2004, respondent filed an answer. In the
answer, respondent denied that the determinations in the 2002
notice were incorrect and requested “that the relief sought in
the petition be denied and that respondent’s determination, as
set forth in the notice of deficiency, be in all respects ap-
proved.”
At various times not disclosed by the record after petition-
ers filed the petition in this case, respondent made requests to
petitioners for information about the $21,267 of gross proceeds
shown in the EquiServe Forms 1099-B. Petitioners did not provide
any information or explanation in response to those requests.
As discussed above, respondent included in the 2002 notice
the address of each payer who provided respondent with an infor-
mation return with respect to Mr. Kim or Ms. Kim, including the
address of Equiserve shown in the EquiServe Forms 1099-B and the
account number for Ms. Kim shown in those forms. Nonetheless, on
August 24, 2005, petitioners sent respondent a letter that stated
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007