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The issues for decision are: (1) Whether petitioner was
required to report as income certain amounts he received in
taxable year 1996; (2) whether petitioner is liable for self-
employment tax on income received in 1996, and entitled to a
deduction therefor, as determined by respondent; and (3) whether
petitioner is eligible for the earned income credit for 1996.
Some of the facts have been stipulated and are so found.1
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Oklahoma City, Oklahoma, on the date the petition was filed in
this case.
Petitioner timely filed his Federal income tax return for
taxable year 1996. On his return, he reported $5,831 in wages
received from OTI, Inc. Petitioner received, but did not report
on his return, $1,605 from Nebraska Keno Operators, Inc., and
$8,886 from National Petition Management.
Respondent issued petitioner a statutory notice of
deficiency dated July 1, 1998. Respondent’s determination of
petitioner's tax liability in the notice of deficiency is
1Both petitioner and counsel for respondent signed the
Stipulation of Facts with attached exhibits. Petitioner,
however, added a handwritten note stating that “I, Barry Fiegel,
say ‘no contest’ or ‘nolo contendre’ to this 3-page proposed
Stipulation of Facts. * * * I have no idea whether the enclosed
‘facts’ are true or are not true.” We will continue to treat the
statements made in the document as stipulated, however, because
petitioner admitted the veracity of the stipulation at trial.
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