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Petitioner never filed a Federal income tax return for
1993. Respondent prepared a return for that year, which
determined that petitioner owed tax on the $100,000 lump-
sum payment.
In the subject notice of deficiency, respondent made
adjustments to petitioner's income for 1990, 1991, and
1993. The adjustments for 1990 were resolved by the
parties and are no longer at issue in this proceeding.
Respondent made the following adjustments to petitioner's
taxable income for 1991 and 1993:
1991 1993
Exemptions -0- ($2,350)
Compensation (FBI) -0- 100,000
Itemized deduction/
standard deduction $16,290 (3,700)
Total adjustments 16,290 93,950
The notice describes the adjustment disallowing the
gambling losses claimed in 1991 as follows:
For the taxable year ending December 31, 1991,
you have failed to substantiate the claimed
gambling losses of $19,690. Since this was the
only claimed itemized deduction, you are now
entitled to the standard deduction of $3,400.
Accordingly, your taxable income is increased
$16,290.
The notice describes the adjustment increasing petitioner's
compensation from the FBI in 1993, as follows:
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