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worked in several restaurants during 1991, quitting whenever his
employers pressed him for Social Security information.
Petitioner earned income from these jobs but does not remember
the amounts. Petitioner did not file an income tax return for
1991, because he was concerned about the consequences of working
in contravention of the immigration law. Despite his efforts to
avoid providing required information to his employers, petitioner
did receive one Form W-2 (Wage and Tax Statement) reporting wage
income of $585 for 1991.
During the years in issue, petitioner's brother, Saleh,
owned a restaurant. During 1992, petitioner worked at Saleh's
restaurant by covering for employees who would fail to come in.
He also took Saleh's wife to the market and their children to the
doctor. In exchange for his help, Saleh gave petitioner "some
spending money." Petitioner did not report this income on a
Federal income tax return for 1992. At the time of trial, Saleh
resided in Calhoun and owned a restaurant, the Atlanta Gate.
In September of 1992, petitioner began to cohabit with
Samantha Gibson (Gibson). Gibson was married but separated from
her husband and was employed as a waitress. In addition to wage
and tip income, Gibson received support payments for her two
children. At the time of trial, petitioner and Gibson were
married and living together in Calhoun.
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