Craig A. Bratcher - Page 3

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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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