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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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