Alan G. Vannoord - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               In his petition filed on July 29, 1997, Mr. VanNoord                   
          contested all of respondent's determinations.  At the time the              
          petition was filed, he resided in Grand Rapids, Michigan.  Mr.              
          VanNoord refused to stipulate any facts, appear at trial, or                
          submit a brief.                                                             
               During the years in issue, Mr. VanNoord was employed by                
          Keebler Co. and earned wages of $67,452, $65,584, and $67,527 for           
          1993, 1994, and 1995, respectively.  In 1995, he also received              
          $7,913 of rental income from the Michigan Department of                     
          Management and Budget.  On January 3, 1994, Mr. VanNoord filed              
          with Keebler Co. a Form W-4, Employee's Withholding Allowance               
          Certificate, on which he claimed eight exemptions.  Later that              
          same year, he filed another Form W-4 on which he claimed that he            
          was exempt from Federal income tax withholding.  Because he did             
          not file a new Form W-4 in 1995, Keebler Co. continued to exempt            
          him from withholding for that year.  Mr. VanNoord failed to file            
          Federal income tax returns for 1993, 1994, and 1995, but he filed           
          timely returns for prior years.                                             
               Respondent determined that Mr. VanNoord:  (1) Failed to                
          report wage income for 1993, 1994, and 1995 and rental income for           





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