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Background
Some of the facts have been stipulated and are so found.
The stipulations of facts, supplemental stipulation of facts, and
the attached exhibits are incorporated by this reference. When
the petitions were filed, petitioner resided in Oakland,
California.
For approximately the first 7 months of 2002, petitioner was
employed full time with Versata, Inc., as the vice president of
human resources. Petitioner subsequently received disability
income as a result of a health condition that prevented her from
working.
On May 2, 2004, petitioner untimely filed a 2002 income tax
return on which she reported income from wages, salaries, tips,
etc. of $88,540,4 interest income of $1,134, a taxable refund of
State and local income tax of $6,242, and a Schedule C business
loss of $77,267. On June 17, 2005, respondent issued to
petitioner a notice of deficiency for 2002.
On January 3, 2005, petitioner untimely filed a 2003 income
tax return on which she reported income from wages, salaries,
tips, etc., of $90,250,5 interest income of $779, dividends of
4 The Forms W-2, Wage and Tax Statement, attached to
petitioner’s 2002 return show that she received $51,040.34 from
Versata, Inc., and $37,500 from CNA Group Life Assurance Co.
5 The Form W-2 attached to petitioner’s 2003 return shows
that she received $90,250 from CNA Group Life Assurance Co.
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Last modified: March 27, 2008