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State Farm, as petitioner has never challenged the income
reported on the Form 1099 issued by Dunn.2
According to petitioner, he was surprised when he received
the notice of lien that indicated his 1992 liability exceeded
$10,000. He now claims that he only agreed to the income and tax
reported on his 1992 return because he was under the impression
that the liability reported on the return constituted his entire
liability for that year. As noted, the liability reported on his
1992 return does not include interest, additions to tax, or
penalties. The liability reflected in the notice of lien does.
Petitioner claims that he only agreed to report the income
shown on the Form 1099 issued by State Farm because he thought
that he could afford to pay the resultant Federal income tax
liability through the installment agreement. He claims that
respondent, in effect, violated the terms of the installment
agreement by subsequently demanding a higher monthly payment than
originally agreed.
Petitioner now takes the position that the income reported
on the Form 1099 issued by State Farm was actually paid to W.H.Y.
He admits that he received the check, but claims that he turned
it over to officials of W.H.Y. He further claims that he did not
2 Petitioner argued at trial that he was not required to
file a 1992 Federal income tax return because of the amount of
income he earned during that year. Even were we to consider only
the uncontested income reported on the Form 1099 issued by Dunn,
this argument would fail. See sec. 6012(a).
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Last modified: May 25, 2011