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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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