and adopts the opinion of the Special Trial Judge that is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: Respondent determined a
deficiency in petitioner's 1990 Federal income tax in the amount
of $8,677 and additions to tax pursuant to sections 6651(a) and
6654(a) in the amounts of $1,786 and $458.78, respectively.
Petitioner resided in Ridgefield, Connecticut, at the time the
petition was filed.
The issues are (1) whether petitioner had unreported income
from The Brownson Institute, (2) whether petitioner had itemized
deductions exceeding the standard deduction amount, and (3)
whether the additions to tax are applicable.
The facts may be summarized as follows. Prior to 1989
petitioner had been a seminary student in Philadelphia,
Pennsylvania. In 1989 petitioner left the seminary and moved to
Washington, D.C., to seek employment as a professional writer.
By the end of 1989, petitioner had accepted a job as a speech
writer with the U.S. Department of Energy (DOE). This
appointment was subject to obtaining a security clearance;
however, petitioner began working as an employee in either late
1989 or very early in 1990, and the security clearance was
obtained in February or March of 1990. During this time
1(...continued)
references are to the Tax Court Rules of Practice and Procedure.
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