$956 and $1,213, and the accuracy-related penalties were in the
amounts of $191.20 and $242.60, for the calendar years 1991 and
1992, respectively.
The issues for decision are: (1) The amount of income from
tips that petitioner is required to report for each of the years
here in issue, and (2) whether petitioner is liable for the
accuracy-related penalties as determined by respondent.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
During the years 1991 and 1992, and for a number of years
prior thereto, petitioner worked as a waitress at Angelo's Steak
Pit restaurant (Angelo's) in Panama City Beach, Florida.
Petitioner's legal residence at the time she filed her petition
in this case was in Panama City, Florida. Petitioner filed her
Federal income tax returns for the years 1991 and 1992, reporting
both wage income and tip income. Petitioner was an experienced
waitress during the years here in issue. She had been working as
a waitress for approximately 24 years.
Angelo's was a seasonal restaurant open only during the
months March through September. In 1991 petitioner worked at
Angelo's 147 days during the months March through September, and
in 1992 she worked 157 days at Angelo's during these months.
Petitioner worked the dinner shift from approximately 4 p.m.
until 9:30 or 10 p.m. each day she worked. About 20 percent of
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