- 2 -
As discussed below, we reject petitioner frivolous tax
protester arguments and sustain respondent's determination.
Section references are to the Internal Revenue Code in
effect in the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
Background
A. Petitioner
Petitioner was married when he filed his petition in this
case and lived in Roswell, Georgia. Petitioner's wife filed a
Federal income tax return, Form 1040, for 1992 in which she
itemized her deductions.
B. Petitioner's Income
Petitioner received $66,978 in nonemployee compensation in
1992 from the following sources: (1) $2,106 from Massachusetts
General Life Insurance Co.; (2) $3,822 from Pioneer Life
Insurance Co. of Illinois; (3) $1,804 from Western Fidelity
Marketing, Inc.; (4) $48,602 from National Group Life Insurance
Co.; and (5) $10,644 from Pyramid Life Insurance Co. In 1992, he
received $22 in interest from Provident Bank and $9 in interest
from Bank South and he forfeited $15 in interest from Provident
Bank. In 1992, Twentieth Century Investors, Inc., paid
petitioner $30 for capital stock for a $30 capital gain.
Twentieth Century Investors, Inc., also paid petitioner $3 in
1992, $2 of which was a dividend and the remaining $1 of which
was a capital gain.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011