- 4 -
On August 9, 1994, respondent mailed petitioner a statutory
notice of deficiency determining an increase of $1,163 in
petitioner's 1991 tax liability. On November 10, 1994,
petitioner filed her petition with this Court, and on January 17,
1995, respondent filed her answer.
From January through early June of 1995, respondent's
Appeals Office and petitioner conducted settlement discussions.
On June 11, 1995, petitioner mailed respondent's Appeals Office a
letter with attached copies of billing records showing that
petitioner had received $2,462 from Dr. Imhoff. The letter noted
that the $2,462 amount was only $35 higher than the amount
reported as miscellaneous income on the return. Petitioner
proposed that respondent concede the $35 understatement. Also
around this time, respondent obtained from Dr. Imhoff copies of
checks paid to petitioner and ledgers maintained by Dr. Imhoff's
office. After June 11 but prior to July 27, 1995, respondent
concluded that: (1) The Form 1099-MISC prepared by Dr. Imhoff,
which reported that petitioner had been paid $4,147.50,
overstated amounts paid by $631.75; (2) the correct amount of
wages from Dr. Imhoff was $3,515.75; (3) petitioner had
understated income by $1,088.50 ($3,515.75-$2,427.25 of
miscellaneous income reported on petitioner's return); (4) the
$1,088.50 understatement resulted from petitioner's failure to
report checks from Dr. Imhoff of $703.50, $350, and $35; and (5)
petitioner qualified as an employee and would not be liable for
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011