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Respondent determined a deficiency in petitioner's Federal
income tax for 1993 in the amount of $1,416.
The issue for decision is whether petitioner received and
failed to report income during 1993.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Charlottesville,
Virginia, on the date the petition was filed in this case.
Petitioner's occupation was not revealed in his petition or
by the evidence presented at trial. From the limited record in
this case, we have gleaned that petitioner worked as a
construction laborer. On his 1993 return, petitioner reported
receiving the following amounts during 1993:
S. Di Gregorio & Son, Inc. $7,692
L. F. Jennings, Inc. 1,587
Dulles Drywall, Inc. 870
Charles Town Races, Inc. 684
In the statutory notice of deficiency, respondent determined
that petitioner received and failed to report: (1) Employee
wages in the amount of $300 from American Property Construction
Company (American); (2) nonemployee compensation in the amount of
$2,099 from D&B Associates, Inc. (D&B); and (3) nonemployee
compensation in the amount of $2,025 from Bryant Dickinson
Drywall (Bryant).
Respondent's determinations in the statutory notice of
deficiency are presumed to be correct, and petitioner bears the
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