- 6 - 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 liablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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