Michael K. Jones - Page 4

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            might be generated by The Questioning Catholic.  Petitioner                                
            returned to the seminary in September of 1990, and completed his                           
            studies.  As of the date of trial petitioner has not written the                           
            book, nor has he repaid the loan.                                                          
                  Respondent received a Form W-2 from DOE showing wage income                          
            of $30,907 and a Form 1099-MISC from the Institute reflecting the                          
            payment of $10,000 to petitioner.  Respondent also received a                              
            Form 1099-INT from Perpetual Savings Bank indicating an interest                           
            payment in the amount of $64 and a Form 1099-G from the                                    
            Commonwealth of Virginia indicating payment of a State tax refund                          
            in the amount of $279.  Petitioner does not recall receiving the                           
            Form 1099-MISC from the Institute.                                                         
                  While petitioner filed returns in the past, he does not                              
            recall whether he prepared or filed a return for 1990.                                     
            Respondent did not receive a return for petitioner's 1990 taxable                          
            year, and prepared a substitute return for him.  Respondent                                
            determined that the wages, interest, and State tax refund were                             
            includable in gross income.  Respondent also determined that the                           
            $10,000 payment received from the Institute was includable in                              
            gross income.  In determining petitioner's tax liability,                                  
            respondent allowed one personal exemption and the standard                                 
            deduction of a single filer in the amount of $3,250.  Respondent                           
            also determined that petitioner was liable for the tax on self-                            
            employment income on the $10,000 payment received from the                                 
            Institute.                                                                                 




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