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net losses from self-employment on Schedule C of $4,769 and
$3,981, respectively.
The only receipts that petitioner reported on Schedule C of
her 1992 income tax return were the settlement proceeds of her
auto accident personal injury claim and the settlement proceeds
of the State Farm class action lawsuit. She lumped these
together and reported the sum as subject to “exclusion under
section 104(a)(2) (see 8275)”. On her 1992 income tax return,
petitioner reported her occupation as “Investor”.
Petitioner earned no income from self-employment for the
1993, 1994, and 1995 tax years. On her income tax returns for
these years, petitioner reported her occupation as “Investor”.
On the Schedule C to her 1996 income tax return, petitioner
reported a $5,364 net loss from self-employment; she reported her
occupation as “Investor”.
At no time did petitioner perform services for State Farm.
Petitioner did not work in the insurance industry after 1977.
Petitioner did not claim any deduction for contributions to a
pension plan on her income tax return for the 1992 tax year.
In her petition, filed with this Court on July 7, 1998,
petitioner raised the issue of the deductibility of her pension
plan contributions for the first time. In her petition,
petitioner claimed a deduction for her 1992 tax year for $91,094
in total contributions to the TJM Pension Plan. The $91,094 in
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