- 5 - Note that the referenced form [Form 1040, December 31, 1990], which sets forth my circumstances and facts, does not take into account the sum of $1,932 reported by the District of Columbia Government on Form 1099-G. The omission is deliberate. The sum in question constitutes court-awarded damages for defamation of character, not self-employment income. The rule is that damages so awarded are not includible in gross income. The petition in this case was filed March 15, 1995. Although petitioner was advised by earlier opinions of the Court of the lack of merit in her positions with respect to losses from her tutoring activity and of the necessity of producing records to substantiate deductions, she made no attempt to comply with the applicable rules. These proceedings have been instituted or maintained by petitioner primarily for delay. OPINION By the time of trial in this case, petitioner had lost four consecutive cases in this Court with respect to her tutoring and counseling activity. In those cases, deductions were denied because she had failed to establish that the activity was conducted with an actual and honest profit objective and because she failed to maintain adequate records of her deductible expenses. In one of those cases, the Court had imposed an award under section 6673 against petitioner because of her persistence in litigating the same issue previously decided against her without any change in facts or applicable law.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011