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Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether the income
petitioner earned during 1999 is subject to Federal income
taxation; and (2) whether the deficiency determined in the
statutory notice of deficiency may be increased. Petitioner
resided in Fayetteville, North Carolina, on the date the petition
was filed in this case.
For taxable year 1999, petitioner submitted to the Internal
Revenue Service a Form 1040A, U.S. Individual Income Tax Return.
On this form, petitioner entered zeroes on the lines provided for
the amounts of income, deductions, and taxes due, but he claimed
an overpayment of $3,011 from withholding on certain wages he
earned. Attached to this form were four Forms W-2, Wage and Tax
Statement, reflecting total taxable wages of $32,296. There also
was attached one Form 1099-R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc. This form reflected a taxable distribution of
$13,123. None of this income was reflected on the face of the
Form 1040A. Respondent asserts that petitioner also received--in
addition to the amounts reflected on the attachments to the Form
1040A--wage income of $1,000 and self-employment income totaling
$3,156. Taking into account each of these items of income,
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