Mark Christopher and Nancy Louise Corcoran - Page 3




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          Department.  Mrs. Corcoran received $25,761 from the Roman                  
          Catholic Bishop of San Diego with respect to her teaching job.              
          Petitioners also received interest on their bank account                    
          balances.  In total, petitioners received compensation for                  
          services of $44,803, unemployment compensation of $168, and                 
          interest of $426.  Petitioners jointly filed a 1998 Federal                 
          income tax return.  They filled in lines 7 through 56 of their              
          Form 1040, U.S. Individual Income Tax Return, with a zero on each           
          line and claimed a refund of $937.90.  Petitioners attached to              
          their tax return a Form W-2, Wage and Tax Statement, reporting              
          wages of $25,761 from Mrs. Corcoran’s employer.  Respondent                 
          treated the $25,761 as if it were properly reported on the tax              
          return.                                                                     
               Petitioners stipulated that they received all the amounts              
          that their employers reported to the Internal Revenue Service on            
          Forms W-2, as wages or compensation paid to them.  However,                 
          petitioners refused to stipulate that such amounts constitute               
          wages.  Petitioners also stipulated that they received all of the           
          unemployment compensation and interest that respondent determined           
          were income.  Petitioners do not challenge the facts on which               
          respondent’s determinations are based or respondent’s calculation           
          of tax.  Rather, petitioners, by selectively analyzing statutes,            
          regulations, and judicial authorities out of context, have                  
          reached the conclusion that their compensation for services,                






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