- 8 - Petitioner contends that he has no deficiencies in income tax because he deposited more funds with respondent than the amount of taxes respondent contends he owes for the years in issue. We disagree. First, petitioner has not shown that he deposited funds with respondent. Second, the term “deficiency” is generally defined by statute as the difference between the total amount of tax that the Commissioner determines should have been reported on the return and the amount that the taxpayer reported on the return. Sec. 6211(a). The amount of a deficiency is not reduced by amounts of tax deposited by or withheld from the taxpayer. Petitioner testified that the payments he received from the Federal Government were nontaxable disability payments. His testimony was uncorroborated. We are not convinced that petitioner was paid on account of disability in any of the years in issue. 2. Whether Petitioner Had $1,092 in Income From Lottery Winnings in 1993 Petitioner contends that he is not taxable on the $1,092 that he won in the lottery in 1993 because he and another individual shared the winnings. Petitioner’s claim is unconvincing because he did not identify the other alleged lottery winner or otherwise corroborate his claim.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011