Hubert R. G. Raney - Page 3




                                        - 3 -                                         
                                  FINDINGS OF FACT                                    
               Petitioner resided in Tampa, Florida, at the time he filed             
          his petition.  Petitioner was married and had no dependent                  
          children during the years in issue.                                         
               Petitioner was employed by the U.S. Postal Service.  During            
          the years 1994, 1995, and 1996, petitioner received wage income             
          from the U.S. Postal Service in the amounts of $34,490, $35,261,            
          and $35,428, respectively.  Petitioner received Forms W-2, Wage             
          and Tax Statement, from the U.S. Postal Service reflecting these            
          wages.  Petitioner also received pension income from the Defense            
          Finance and Accounting Service for the years 1994, 1995, and 1996           
          in the amounts of $6,258, $6,420, and $6,591, respectively.                 
               Petitioner provided the U.S. Postal Service with Forms W-4,            
          Employee’s Withholding Allowance Certificate, dated February 15,            
          1994, and April 7, 1993; he claimed 15 withholding allowances on            
          each form.  The U.S. Postal Service withheld Federal income taxes           
          from petitioner’s wages in the amounts of $183.95, $7.84, and               
          $112 for the years 1994, 1995, and 1996, respectively.                      
          Petitioner made no estimated tax payments for the years in issue.           
               Petitioner sent Forms 1040, U.S. Individual Income Tax                 
          Return, to respondent for the years in issue.  The Forms 1040               
          were received by the Internal Revenue Service on December 17,               
          1997.  On those Forms 1040, petitioner reported no income.                  
          Respondent did not accept the above-referenced Forms 1040 as tax            






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