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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 36
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