- 3 - Department. Mrs. Corcoran received $25,761 from the Roman Catholic Bishop of San Diego with respect to her teaching job. Petitioners also received interest on their bank account balances. In total, petitioners received compensation for services of $44,803, unemployment compensation of $168, and interest of $426. Petitioners jointly filed a 1998 Federal income tax return. They filled in lines 7 through 56 of their Form 1040, U.S. Individual Income Tax Return, with a zero on each line and claimed a refund of $937.90. Petitioners attached to their tax return a Form W-2, Wage and Tax Statement, reporting wages of $25,761 from Mrs. Corcoran’s employer. Respondent treated the $25,761 as if it were properly reported on the tax return. Petitioners stipulated that they received all the amounts that their employers reported to the Internal Revenue Service on Forms W-2, as wages or compensation paid to them. However, petitioners refused to stipulate that such amounts constitute wages. Petitioners also stipulated that they received all of the unemployment compensation and interest that respondent determined were income. Petitioners do not challenge the facts on which respondent’s determinations are based or respondent’s calculation of tax. Rather, petitioners, by selectively analyzing statutes, regulations, and judicial authorities out of context, have reached the conclusion that their compensation for services,Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011