Donald W. Wolgamott - Page 2

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          except as noted below.  Petitioner resided in Seattle,                      
          Washington, on the date the petition was filed in this case.                
               During 1997, petitioner received $10,186 from the State of             
          Washington as deferred compensation.  Petitioner failed to report           
          any of this amount on his 1997 Federal income tax return.  In               
          1997, petitioner also received $3,072 from the State of                     
          Washington Employment Security Department as unemployment                   
          compensation.  Petitioner reported only $2,608 of unemployment              
          compensation on his 1997 Federal income tax return.2  On his tax            
          return, petitioner also understated the amount of wages withheld            
          by $305.                                                                    
               Respondent’s adjustments increase petitioner’s wage income             
          by $10,186, and his unemployment compensation by $464, and                  
          increase the amount of tax withholding by $305.  The deficiency             
          notice determines an increase in tax of $2,982 and states that              
          because of the increase to withholding petitioner owes additional           
          tax of $2,677 for 1997.                                                     
               Petitioner argues that because of “major computer problems”            

               2The parties stipulated that during 1997, petitioner                   
          received unemployment compensation of $3,072, and that none of it           
          was reported on his Federal income tax return for 1997.                     
          Actually, petitioner reported $2,608 of unemployment compensation           
          for 1997, and respondent seeks an adjustment to the amount of               
          unemployment compensation of only $464 (the difference between              
          $2,608 and $3,072).  Since the stipulation is clearly contrary to           
          facts disclosed in the record to the extent of this mechanical              
          error, we are not bound by the stipulation.  Jasionowski v.                 
          Commissioner, 66 T.C. 312, 318 (1976).                                      

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