- 3 - determination that petitioner failed to report income as reflected in the following schedule: Income 1991 1992 1993 Nonemployee compensation $56,115 $34,726 --- Wages --- 6,780 $25,5411 Interest 36 --- --- Total 56,151 41,506 25,541 1 For 1993, respondent gave petitioner credit for amounts withheld from his taxes insofar as his ultimate tax liability for that year is concerned. However, the determination of a statutory deficiency does not take such amounts into account. See sec. 6211(b)(1). In making the foregoing determinations, respondent relied on Forms 1040X (Amended U.S. Individual Income Tax Return) that petitioner submitted in July 1994 for the taxable years 1991 and 1992. In this regard, the Form 1040X for 1991 disclosed "Total income" in the amount of $56,151, whereas the Form 1040X for 1992 disclosed "Total income" in the amount of $34,726. In making the foregoing determinations, respondent also relied on the following Forms W-2 and 1099 that disclosed the payment of income to petitioner by various third-party payors: 1991 Income Payor Amount Nonemployee compensation A M Cabinets, Inc. $3,535 Interest Founders National Bank 36Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011