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Background
Respondent determined a deficiency in income tax of $17,380
and additions to tax under sections 6651(a)(1) and 6654 of $4,345
and $694.58, respectively, with respect to petitioner's 2001
taxable year. The notice of deficiency specifies that the
adjustments to petitioner’s taxable income are attributable to
petitioner’s failure to file a 2001 tax return2 reporting various
items of income including nonemployee compensation paid by
"Accumen Realty Inc." and "Royal Foridian [sic] by Spinnaker
LLC", and interest paid by First Union National Bank. These
items of income were reported to respondent on Forms 1099 or
other information returns submitted by the payors.
When she filed the petition in this case, petitioner resided
in Florida. Petitioner, acting without counsel, requested a date
and time certain for the trial, and the Court granted her
request. At the appointed time and place for trial, however,
petitioner failed to appear. Instead, counsel retained by
petitioner appeared on her behalf. Upon questioning,
petitioner's counsel represented that he had no witnesses to call
or other evidence to present and, indeed, lacked even authority
1(...continued)
Practice and Procedure.
2 The record demonstrates that petitioner has failed to file
returns since 1993.
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Last modified: November 10, 2007