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Respondent determined a deficiency in petitioner's 1991
Federal income tax in the amount of $840, and an accuracy-related
penalty in the amount of $168. Following a concession,2 the
issue for decision is whether petitioner must include in her 1991
income a cash award received from Wayne State University during
that year.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Detroit, Michigan.
During 1991, petitioner was employed as a professor by Wayne
State University (the university). Her wages from such
employment for that year were $39,441.98. She was the recipient
of the Wayne State University 1991 President's Award for
Excellence in Teaching. Along with the professional distinction
and honor resulting from the award, petitioner received $3,000 in
cash from the university in 1991 in addition to her wages. The
proceeds of the award were paid directly to petitioner and not to
an entity designated by her.
In connection with the award, petitioner received a Form
1099 from the university reflecting the $3,000 payment, from
2Respondent has conceded the sec. 6662(a) accuracy-related
penalty imposed for 1991.
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