John N. Shelton, Jr. - Page 4

                          Taxable Year                                                
               1994       1995         1996       1997                                
          Wage income--U.S.            $45,546.33  $36,170.40  $39,020.91  $45,207.89 
          Postal Service                                                              
          Wage income--Baltimore Area      900.00      900.00    1,000.00    1,000.00 
          Local APWU                                                                  
          Interest income--U.S.             20.00       28.00       24.00       -0-   
          Postal Service Credit Union                                                 
               Petitioner stipulated that he failed to file Federal income            
          tax returns and failed to make estimated tax payments for the               
          taxable years 1994 to 1997, inclusive.                                      
               The Court will treat the stipulations as concessions by the            
          parties resolving the issues of unreported wage income and                  
          interest received for each of the taxable years at issue and the            
          issues relating to the additions to taxes pursuant to sections              
          6651(a)(1) and 6654.                                                        
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, supplemental stipulation of facts, and            
          the exhibits are incorporated herein by this reference.  At the             
          time of the filing of the petition, petitioner resided in                   
          Finksburg, Maryland.                                                        
               Petitioner has been employed by the U.S. Postal Service in             
          the main post office in Baltimore for more than 12 years,                   
          including the taxable years in issue.                                       
               Gross income includes all income from whatever source                  
          derived.  Sec. 61(a).  Section 61(a)(5) specifically includes               
          income derived from rents.                                                  
               During the taxable years in issue, petitioner owned                    

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