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summary judgment.
Background
The record establishes and/or the parties do not dispute the
following:
A. Petitioner’s Tax Liability for 1995
On or about April 15, 1996, Christopher Kiley (petitioner)
and his wife Sabrena S. Legere2 filed with respondent a joint
Federal income tax return, Form 1040PC, for the taxable year
1995. Petitioner listed his occupation as “waiter”, and his wife
listed her occupation as “cashier”.
On their return, petitioner and his wife reported adjusted
gross income in the amount of $41,874, consisting of wages and
tips in the amount of $39,590 and taxable pensions/annuities in
the amount of $2,284.3 After reduction for the standard
deduction and personal exemptions, petitioner and his wife
reported taxable income in the amount of $25,324 and a tax
liability in the amount of $4,143. After reduction for Federal
income tax withheld ($2,871), petitioner and his wife reported
the amount owed as $1,312, consisting of tax in the amount of
2 Ms. Legere did not file with the Court a petition for
lien or levy action. See infra G. Accordingly, she is not a
party to the present proceeding.
3 Petitioner and his wife attached to their return three
Forms W-2, Wage and Tax Statement, showing the payment of wages
and allocated tips, and one Form 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing Plans, etc.,
showing the payment of a taxable distribution.
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