4
A financial analysis schedule for petitioner, generated by
MILICO on December 30, 1992, and received into evidence, reflects
the following information:
Life Insurance1 Earnings2 Net
Year Checks Issued Rep. on 1099 Difference
1988 $12,232.64 $6,098.68 ($6,133.96)
1989 11,113.71 11,210.23 96.52
1990 128.44 7,266.75 7,138.31
1991 333.06 210.22 (122.84)
1992 360.84 -0- (360.84)
Total 24,168.69 24,785.88 617.19
1 Represents advances made to petitioner during year.
2 Represents commissions credited to petitioner's account
after right to funds became unconditional.
On his 1988 and 1989 Federal income tax returns, petitioner
reported as commission income only the amounts reported on the
Forms 1099 issued by MapleLeaf. Petitioner did not report any
commission income received from MapleLeaf on his 1990 return. In
the notice of deficiency, respondent determined that petitioner
failed to report income in 1990 of $7,266.75. Respondent further
determined that petitioner was entitled to a deduction for self-
employment tax in the amount of $517. Respondent concedes that
if we find petitioner failed to report income as determined, he
is entitled to deductions for chargeback expenses of $1,526 and
miscellaneous expenses of $115.
Petitioner concedes that he received the amounts reflected
in the second column of the above schedule for the corresponding
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