Deborah A. Cole - Page 6

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          1991 Form 1099-MISC prepared by Dr. Imhoff.  Petitioner offered             
          to pay the additional income tax associated with the $350 and $35           
          checks as well as the employee portion of the FICA tax.  The                
          determination of the year in which the $703.50 check should be              
          includable, however, remained in dispute.                                   
               On October 6, 1995, respondent acknowledged that petitioner            
          had reported the $703.50 amount on her 1990 income tax return.              
          Although respondent noted that petitioner, a cash basis taxpayer,           
          was required to report income in the year of receipt (i.e.,                 
          1991), respondent agreed to reduce the asserted unreported income           
          for 1991 by $703.50.  Respondent did not concede that petitioner            
          had reported $2,427.25 of the alleged understatement as                     
          miscellaneous income.  On October 11, 1995, respondent changed              
          her position and offered to concede that $2,427.25 of the alleged           
          understatement had in fact been reported as miscellaneous income.           
          After taking these proposed concessions into account, there                 
          remained unreported income of $385, producing an income tax                 
          deficiency of $59 and FICA tax liability of $199, plus interest.            
               On October 16, 1995, the parties filed with this Court a               
          decision document and a stipulation of settled issues.  The                 
          decision document stated that petitioner is liable for a                    
          deficiency of $59 in her 1991 income tax.  The stipulation of               
          settled issues stated that:  (1) Petitioner agrees to pay FICA              
          tax of $199 for 1991; (2) petitioner agrees that she is liable              






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