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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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