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received income for 1992 only in the amounts that the parties
have stipulated.
Respondent asserted that petitioner had unreported self-
employment income during 1993 from the Liberty Foundation.
Respondent based this contention on admissions by petitioner in
her divorce proceeding that she received income from the Liberty
Foundation of $1,600 per month. At trial, respondent argued that
petitioner received income of $11,438 in 1993 from the Liberty
Foundation. Similarly, respondent's trial memorandum presented
the issue regarding petitioner's 1993 self-employment income as
"Whether Petitioner received $11,438 in taxable compensation in
exchange for legal research provided for * * * the Liberty
Foundation during the tax year, 1993." Respondent's trial
memorandum did not identify any other source of self-employment
income for 1993. Respondent's trial memorandum abandoned the
original determination in the notice of deficiency that
petitioner earned self-employment income of $30,764 in 1993,
contending instead that she earned $11,438. On brief, however,
respondent argues that the entire 1993 income and self-employment
tax deficiency is in issue and that petitioner failed to prove
she did not earn $30,764.
Because of respondent's trial memorandum and other
statements made by respondent to petitioner prior to trial,
petitioner believed that the entire 1993 deficiency as set forth
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