Mary Ellen Lepordo - Page 4




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                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  At the time the petition             
          was filed, petitioner resided in Somerville, Massachusetts.                 
               Petitioner is a high school graduate who was employed in               
          clerical positions during the years at issue.  Petitioner and               
          Joseph J. Lepordo filed a joint Form 1040, U.S. Individual Income           
          Tax Return, for each of the years at issue.  The Federal income             
          tax returns for 1996 and 1999 showed tax due in excess of the               
          remittances.  For 1998, 2001, and 2002, the Federal income tax              
          returns were filed without remittances for the tax reported.                
          With respect to 2000, respondent determined a $17,701 deficiency            
          in the notice of deficiency mailed to petitioner and Mr. Lepordo            
          on August 9, 2002.  The deficiency was assessed when they failed            
          to file a petition with the Court.  The taxable years and the tax           
          due for each year are summarized as follows:                                
                    Year                      Tax before credits                      
                    1996                          $8,598                              
                    1998                14,508                                        
                    1999                13,871                                        
                    2000                17,701                                        
                    2001                18,089                                        
                    2002                15,484                                        
               On April 21, 2003, the Internal Revenue Service (IRS)                  
          issued to petitioner and Mr. Lepordo a notice of intent to levy             
          with respect to 1996.  On September 9, 2003, petitioner and Mr.             






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