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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.
Background
The record establishes and/or the parties do not dispute the
following:
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
W-2).2
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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Last modified: May 25, 2011