Tracee Creen - Page 2

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          satisfy the burden of proof under Rule 142(a)1 that respondent              
          has with respect to the increased deficiency in Federal income              
          tax (tax) alleged in respondent’s amendment to answer.                      
               The record establishes and/or the parties do not dispute the           
               At the time petitioner filed the petition, petitioner’s                
          mailing address was in Tryon, North Carolina.                               
               During 1998, Spartanburg Regional Medical Center                       
          (Spartanburg Medical Center) employed petitioner and paid her               
          $16,679.62 in wages.  During that year, Spartanburg Medical                 
          Center deposited all of petitioner’s wages directly into her bank           
          account, except for $99.16 that it paid petitioner by check.                
          Spartanburg Medical Center reported the wages that it paid                  
          petitioner during 1998 in Form W-2, Wage and Tax Statement (Form            
               In the notice of deficiency (notice) issued to petitioner              
          for her taxable year 1998, respondent determined a deficiency in            
          petitioner’s tax of $911 attributable to a State tax refund and             
          certain nonemployee compensation that she received during that              

               1All Rule references are to the Tax Court Rules of Practice            
          and Procedure.  All section references are to the Internal                  
          Revenue Code in effect at all relevant times.                               
               2As reflected in Form W-2, during 1998 Spartanburg Medical             
          Center withheld $1,459.54 in tax from petitioner’s wages.                   

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