Wayne D. Bumgarner - Page 4

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            Valley withheld Federal income tax of $540.20 from the wages paid                            
            to petitioner during 1991.  Petitioner also received unemployment                            
            compensation of $7,904 from the State of Oregon in 1991.                                     
            Furthermore, in that year petitioner earned interest income from                             
            Amvesco, Inc., d/b/a Western Pioneer Title Co., in the amount of                             
            $18.91, and interest income of $58 from the Public Employees                                 
            Federal Credit Union.  No Federal income tax was withheld from                               
            either distribution of interest.                                                             
                  During 1992 and 1993, petitioner received $31,750 and                                  
            $42,000, respectively, in nonemployee compensation from MYCO                                 
            Financial, Inc. (MYCO).  These amounts were reported on Forms                                
            1099-MISC issued to petitioner for each of those years.  No                                  
            Federal income tax was withheld by MYCO from payments made to                                
            petitioner during 1992 and 1993.  Petitioner also received                                   
            unemployment compensation during 1992 in the amount of $1,235                                
            from the State of Oregon.  Also, in 1992 Bumgarner earned                                    
            Schedule A income of $300 from Bungee Masters, Inc. and $13 from                             
            Melaleuca, Inc. (Melaleuca).  In 1993, petitioner received $151                              
            of interest income from one or more unspecified sources.  He also                            
            earned $33 of Schedule A income from Melaleuca in that year.                                 
                                              Discussion                                                 
                  We must decide whether petitioner's wages and nonemployee                              
            compensation should be included in his gross income for income                               
            tax purposes for the years at issue.                                                         






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