Jimmie R. Valentine - Page 5

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          During that year, petitioner also received a taxable retirement             
          annuity distribution in the amount of $5,256 and $34 in interest            
          income from Great Western Bank.                                             
               During 1994, petitioner received nonemployee compensation              
          from Transamerica Occidental Life Insurance Company in the amount           
          of $16,754, a taxable retirement annuity distribution in the                
          amount of $2,883, and $24 in interest income.                               
               None of the foregoing amounts of income that petitioner                
          received during the years at issue was included in any Federal              
          income tax return that he filed.  All compensation paid to J.R.             
          Valentine Lab during those years should have been reported by               
          petitioner as Schedule C income.  Petitioner received no income             
          from nontaxable sources during any of the years at issue.                   
               Petitioner's personal living expenses for 1994 were at least           
          $21,250.                                                                    
               Petitioner is not entitled for any of the years at issue to            
          a dependency exemption for any person other than himself.                   
               Petitioner is entitled to the filing status of single for              
          each of the years at issue.                                                 
               On or about May 1, 1991, the Internal Revenue Service                  
          received a check in the amount of $8,500 from petitioner that was           
          dated April 15, 1991.                                                       
               Petitioner has the burden of showing error in the                      
          determinations of respondent in the notices.  Rule 142(a); Welch            
          v. Helvering, 290 U.S. 111, 115 (1933).                                     




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