- 6 - 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 forthPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011