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W-2 issued to petitioner by Swink. Apparently, petitioner was
required to reimburse Swink for certain trading losses and
customer bad debts. It is unclear whether the compensation
reported on the Form W-2 is net of reimbursements petitioner made
to Swink for trading losses and customer bad debts. Sometime in
1992 or 1993, petitioner discarded all records relating to 1989
that he might have kept.
Respondent's Information Returns Master File transcript
indicates that two payors issued information returns to
petitioner for 1989, one from Swink and the other from Worthen
Bank and Trust Co.
The notice of deficiency upon which this case is based was
issued and mailed to petitioner on September 18, 1996. In that
notice of deficiency, adjustments to petitioner's 1989 income
were made as though he did not file a Federal income tax return
for that year. Specifically, respondent (1) increased
petitioner's income by the amount of compensation reported on the
W-2 issued to petitioner by Swink; (2) increased petitioner's
income by $44 attributable to a distribution from Worthen Bank
and Trust Co.; (3) allowed petitioner a personal exemption
deduction; and (4) allowed petitioner the standard deduction
applicable to a single individual. Also in the notice of
deficiency, respondent determined that the additions to tax under
sections 6651(a)(1) and 6654 are applicable.
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