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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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