Lavonne Allen Hodgson - Page 2

                                        - 2 -                                         

               All section references are to the Internal Revenue Code in             
          effect for 1994, and all Rule references are to the Tax Court Rules         
          of Practice and Procedure.                                                  
               Petitioner resided in Santa Maria, California, at the time he          
          filed his petition.                                                         
               During 1994, petitioner was employed as an engineer for the            
          Northrop Grumman Corp., for which he was paid $67,337 for services          
          rendered. On his 1994 Federal income tax return, petitioner                 
          reported the wages from his employment, but claimed a deduction in          
          an   amount    equal   to    the    wages   for    "Non Taxable             
          Compensation/Renumeration Eisner vs McComber [sic] 252 US 189".  As         
          a result, petitioner reported no taxable income and claimed a               
          $12,342 refund due to the Federal income taxes withheld by his              
          employer during the year.1  Above his signature on the return,              
          petitioner stamped the words "'Under Protest' UCC 1-207".                   
               In his petition, filed September 30, 1996, petitioner stated           
          that he "disagree[d] with the disallowance of compensation for              
          labor as non-taxable income."  During October and November 1997,            
          petitioner served on respondent two requests to produce documents,          
          a set of interrogatories, and requests for admissions, all seeking          
          the  factual  and  legal  basis  for  respondent's  deficiency              

               1    The Internal Revenue Service "froze" the refund and               
          applied it as a prepayment credit against the 1994 deficiency.              

Page:  Previous  1  2  3  4  5  Next

Last modified: May 25, 2011