Peter Paul Lagasse - Page 2

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            income tax in the amount of $7,228 and an addition to tax under                               
            section 6651(a)(1) in the amount of $215.                                                     
                  The issues for decision are:  (1) Whether petitioner                                    
            received taxable wages and unemployment compensation in the                                   
            amounts determined by respondent and (2) whether petitioner is                                
            liable for the addition to tax under section 6651(a)(1) for                                   
            failure to file a return.                                                                     
                  The parties were unable to agree on a stipulation of facts                              
            in this case.  Our findings of fact are based on the record                                   
            consisting of testimony of witnesses and documents submitted into                             
            evidence.                                                                                     
                  During the period December 1992 through mid-February 1993,                              
            petitioner was unemployed.  During the period January 6 through                               
            February 8, 1993, the State of Connecticut issued seven checks in                             
            the amount of $198 each, for a total of $1,386, as unemployment                               
            compensation to petitioner.  The Connecticut Department of Labor                              
            records further reflect that each of the seven payments to                                    
            petitioner was designated as $288; however, $90 was offset from                               
            each payment to pay an outstanding child support order.                                       
            Accordingly, the total payments for unemployment insurance in                                 
            1993 paid on behalf of petitioner were $2,016 (7 X $288) although                             
            petitioner was sent checks totaling $1,386 (7 X $198).  A total                               
            of $630 was sent to the Connecticut court to be applied against                               
            the outstanding court order for child support.  Sometime during                               
            the last week of January 1994, petitioner was sent a Form 1099                                




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