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indicating he earned wages of $24,800. No Federal income tax was
withheld from petitioner’s pay in accordance with the Form W-4,
Employee’s Withholding Allowance Certificate, completed by
petitioner indicating that he was “exempt”. Neither Tech-Power
nor United Defense required petitioner to attend educational
courses or purchase supplies or equipment as a condition of his
employment. Petitioner received unemployment compensation from
the State of Colorado in 1996, which was mailed to him at an
address in Illinois. Also during 1996, petitioner stored
personal belongings at a storage facility in Iowa.
Petitioner did not file a Federal income tax return for
taxable year 1995. For taxable year 1996, he did not file a
return prior to the time respondent issued him a statutory notice
of deficiency for that year. Although only what appears to be
the cover page of the notice of deficiency is in the record,
respondent explains the deficiency in his trial memorandum as
resulting from wage income of $24,800 and unemployment
compensation of $4,223.1 On October 12, 2000, after filing the
1Although we do not have before us the basis of respondent’s
determinations in the notice of deficiency, both parties agree as
to what issues are before the Court. Furthermore, it is evident
that respondent’s calculation of petitioner’s tax liability was
determined as follows:
Wages $24,800.00
Unemployment compensation 4,223.00
Standard deduction (4,000.00)
Personal exemption (2,550.00)
Taxable income 22,473.00
Tax (from 1996 tax table) 3,371.00
(continued...)
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