Edward A. Drozdowski and Diana D. Drozdowski - Page 3




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          Forms W-2 relating to, his wages.  CPC employed Mrs. Drozdowski             
          in 1988, 1989, and 1990.  At Mrs. Drozdowski's request, CPC                 
          withheld taxes from, and issued Forms W-2 relating to, her wages.           
          During 1990, CPC was purchased by Continental Card Acquisition              
          (CCA).  CCA employed Mr. Drozdowski for the remainder of 1990,              
          withheld taxes from his wages, and issued him a 1990 Form W-2.              
          On their income tax returns for the years in issue, petitioners             
          reported Mrs. Drozdowski's wages from CPC and Mr. Drozdowski's              
          wages from CCA but did not report Mr. Drozdowski's wages from               
          CPC.                                                                        
            In March 1994, Mr. Drozdowski was charged, pursuant to section            
          7201, with evading income tax relating to 1989.  Mr. Drozdowski             
          pleaded guilty to the charge, was sentenced to 3 years'                     
          probation, and was ordered to pay a fine and restitution.                   
          Pursuant to the plea agreement, petitioners amended their tax               
          returns for the years in issue to report Mr. Drozdowski's wages             
          from CPC.                                                                   
                                       OPINION                                        
            Respondent determined that petitioners failed to report Mr.               
          Drozdowski's wages from CPC for 1987, 1988, 1989, and 1990.                 
          Petitioners concede that they failed to report Mr. Drozdowski's             
          wages from CPC for the years in issue but contend that the                  
          payments Mr. Drozdowski received were net of income tax                     
          withholdings.  In effect, petitioners contend that the amount of            





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