- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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