Linda Sanders - Page 6

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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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