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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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Last modified: March 27, 2008