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petitioners' 1993 Federal income tax in the amount of $4,877 and
an accuracy-related penalty under section 6662(a) in the amount
of $975.2 After a concession by respondent,3 the issue for
decision is whether, for the purposes of the alternative minimum
tax, petitioner Chander Kant (petitioner) was an employee with
respect to items of income and expense related to his activities
in Singapore.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners resided in Short Hills,
New Jersey, at the time that the petition was filed.
Petitioner is an associate professor of economics at Seton
Hall University (Seton Hall), and petitioner Ashima K. Kant (Ms.
Kant) is an associate professor of nutrition at Queens College,
City University of New York. In June 1993, Seton Hall granted
petitioner's request for sabbatical leave. In his application,
petitioner maintained that a sabbatical leave would "result in at
least two papers publishable in respectable journals, and will
2 Respondent claimed an increased deficiency in her answer
to petition in the amount of $960 (for a total deficiency of
$5,837), asserting that petitioners were not entitled to a
claimed child care credit. The parties agree that petitioners'
entitlement to the claimed child care credit is contingent upon
our determination of the other issues. Therefore, we do not
separately address this issue.
3 Respondent concedes that petitioners are not liable for
the accuracy-related penalty under sec. 6662(a).
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