Barry S. Michelson - Page 3

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          Massachusetts.2  See sec. 7503.  However, petitioners did not               
          file their 1991 joint return until October 26, 1994, after                  
          individual notices of deficiency had already been issued to each            
          spouse.                                                                     
               During the taxable year 1991, Barry was a self-employed                
          consultant.  On Schedule C of their 1991 return, petitioners                
          reported a net $24,572 loss with respect to Barry's consulting              
          activities.  During 1991, Barry received compensation in the                
          total amount of $634, summarized as follows:                                

          Employer                   Amount           Withholdings                    
          City of Stamford      $165                  -0-                             
          Town of Greenwich     469                   -0-                             


               During 1991, Shelley received wages from AMBAC Indemnity in            
          the total amount of $100,571.97, from which her employer withheld           
          Federal income taxes in the amount of $17,831.11.  She received             
          dividends from Manufacturer's Hanover Trust, as transfer agent,             
          in the amount of $652, from which Manufacturer's withheld Federal           
          income taxes in the amount of $128.  She also received interest             
          income from Citybank in the amount of $1,203, from which the bank           
          withheld Federal income taxes in the amount of $240.                        

          2Although petitioners resided in Connecticut, their return                  
          was to be filed with the Andover Service Center in Andover,                 
          Massachusetts.  Whether the filing date is a legal holiday is               
          determined by reference to the State where the internal revenue             
          district office is located.  Sec. 7503.                                     




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