Rose Lynn Richmond - Page 5




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          the period of limitations governing collection remained open with           
          regard to assessments for the taxable years 1982 and 1985 that              
          were recorded in 1986.                                                      
               The record does not reflect whether petitioner filed a                 
          refund suit in Federal District Court or the Court of Federal               
          Claims with regard to her refund claims for the taxable years               
          1982 and 1985.  See sec. 6532(a) (a taxpayer may file a refund              
          suit under section 7422 after 6 months from the date of filing a            
          claim for refund and within 2 years from the date of mailing of a           
          notice of disallowance).                                                    
          Petitioner’s Tax Liability for 1998                                         
               Petitioner failed to file a tax return for 1998.   On                  
          February 5, 2001, respondent filed a substitute for return for              
          the taxable year 1998 on petitioner’s behalf.  On April 30, 2001,           
          respondent mailed to petitioner a notice of deficiency for 1998.            
          Petitioner filed a petition for redetermination with the Court              
          (assigned docket No. 9419-01) challenging the notice of                     
          deficiency.                                                                 
               The deficiency respondent determined for petitioner’s 1998             
          taxable year was $87,811.  The notice of deficiency included as             
          an attachment a tax calculation summary in which respondent                 
          acknowledged that petitioner was entitled to a credit of $24,844            
          for tax withholding during 1998.  The $24,844 amount comprised              
          $13,665 withheld from petitioner’s wages and $11,179 withheld               







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