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December 31, 2001; and December 31, 2002. By letter dated
November 7, 2006, respondent notified petitioner in writing that
the documents did not support respondent’s consideration or
allowance of any deductions, exemptions, or credits from or
against her individual income or income taxes. Although the date
by which petitioner was to submit documentation pursuant to the
Court’s order had passed, respondent requested that petitioner
provide substantiation of any items she would like to be
considered. Petitioner failed to provide any further
substantiation, responding only with a letter containing a
spurious attack on respondent’s counsel. Neither party has
requested further trial of these cases.
The Forms 1120S that were submitted by petitioner to
respondent reported “Compensation of officers” of $325,304;
$214,114; and $256,811, which corresponded to the amounts
determined by respondent for 2000, 2001, and 2002, respectively.
In addition, the Forms 1120S reported ordinary income distributed
to petitioner as the sole S corporation shareholder of $116,493;
$247,729; and $161,859 for 2000, 2001, and 2002, respectively.
The shareholder distributions were not included in the amounts of
income determined in respondent’s statutory notices. The Social
Security number shown for petitioner on the Forms 1120S is not
the same as the Social Security number shown for petitioner on
her Forms 1040 and on the petitions filed in these cases. The
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Last modified: May 25, 2011