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The issues are (1) whether petitioner Louis Bonner, Jr.
(petitioner), had unreported income of $25,980, and (2) whether
petitioners are liable for the section 6662 penalty. Petitioners
resided in Shreveport, Louisiana, at the time they filed their
petition.
The facts may be summarized as follows. Petitioners filed a
joint Federal income tax return for 1998 on which they reported
wage income for petitioner Celeste Bonner of $11,986 and interest
income of $59. Petitioner did not report any income from self-
employment or wages.
Petitioner is a cabinetmaker. Jerry Brown is a contractor
who does reconstruction of residential properties. His wife,
Linda Brown, operates a “craft business” that sells, inter alia,
dowry chests. Mrs. Brown keeps the records for both endeavors,
which are operated as a single business for tax purposes under
the Browns’ name. The Browns issued a Form 1099-MISC,
Miscellaneous Income, to petitioner in the amount of $25,980 for
services as a self-employed individual. Petitioner contends that
he received only $1,200 in income from the Browns in 1998.
The issue is totally factual–-viz, did petitioner receive
income of $25,980 from the Browns--and turns on whether we
believe petitioner or the Browns. We believe the Browns.
Both Mr. and Mrs. Brown testified that they used the
services of petitioner to build cabinets and chests during 1998.
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