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letter that stated in pertinent part:
We made written requests to you twice to receive copies
of the documents as stated in the previous letters.
But, we have not received any response from you.
We again request copies of the documents in relation to
unreported investment income. If we do not hear from
you very soon, we may notify this matter to Tax Court
judge. [Reproduced literally.]
On September 30, 2005, respondent sent petitioners a letter
in which respondent restated the information shown in the
EquiServe Form 1099-B’s that respondent had summarized in the
2002 notice, including the address of EquiServe and the account
number of Ms. Kim shown in such forms.
At a time not disclosed by the record after petitioners
failed to provide any information or explanation in response to
respondent’s requests to them for information about the $21,267
of gross proceeds shown in the EquiServe Forms 1099-B, but before
December 2005, respondent asked Computershare (formerly
EquiServe) for information about such gross proceeds shown in
such forms. Respondent also asked Fannie Mae for any relevant
information.
On a date in December 2005 before December 19, respondent
received certain information from Fannie Mae relevant to the
$21,267 gross proceeds determination. Based upon that informa-
tion, respondent concluded (1) that the total wages, tips, and
other compensation shown in the Fannie Mae Form W-2 included an
amount of compensation, i.e., $4,234.94, resulting from Ms. Kim’s
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Last modified: November 10, 2007