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Form 1099 information. That same Form 1099 information also
shows that $6,408 was withheld from the Phillips Petroleum Co.
royalty income. Respondent did not give credit to petitioner for
this withholding, in calculating the 1984 additions to tax under
sections 6651(a)(1), 6653(a)(2), and 6661(a). The effect of this
credit will be determined in the computations under Rule 155.
Thus, apart from the 1984 withholding (which in any event
does not affect the amount of the deficiency), the little
evidence that is in the record supports respondent's
determination for 1984 and 1986. In any event, petitioner has
failed to carry his burden of proving respondent's determinations
to be in error for these years. Rule 142(a); Welch v. Helvering,
supra.
From the foregoing we conclude, and we have found (supra
table 6), that petitioner received and failed to report royalty
income in the amounts of $29,596 for 1984 and $13,230 for 1986.
We hold for respondent on this issue.
(2) 1985
Petitioner reported $21,641 royalty income on his 1985 tax
return; respondent determined that the correct amount was
$23,954. Supra table 6.
The parties stipulated to Exhibit J as "A summary of Forms
1099 and Forms W-2 for the taxable year 1985". Exhibit J is what
the Internal Revenue Service refers to as an IRP document.
Exhibit J shows five Forms 1099, from four payors, reporting 1985
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