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The issues for decision are: (1) Whether petitioner is
required to include $138,799.18 in compensation for services,
backpay, and interest on backpay in her 1992 gross income; (2)
whether petitioner is required to include a $182 State income tax
refund and $15 of interest in her 1992 gross income; and (3)
whether petitioner is liable for an addition to tax under section
6651(a)(1) for failure to timely file her 1992 Federal income tax
return.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Philadelphia, Pennsylvania, at the time she filed her petition.
Petitioner was a reading specialist for the School District
of Cheltenham Township (district) until June of 1989. In June of
1989, the district asked petitioner not to return to work the
following school year, and in August of 1989, she was suspended
from her position with the district. In November of 1989, the
district’s school board (board) voted to dismiss petitioner for
willfully violating school laws when she failed to follow
directives of superiors. Petitioner appealed the board’s
decision to dismiss her. On January 24, 1990, the secretary of
education for the Commonwealth of Pennsylvania (secretary)
reversed the board’s decision and ordered the district to
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