- 4 - determined that petitioner Shari L. Hartz received unreported wage income of $13,595 in 1996. Gross income generally includes all income from whatever source derived, including compensation for services and gross income derived from business. Sec. 61(a)(1) and (2). In his trial memorandum, respondent argues as follows with respect to the unreported income: Gross receipts of $140,559 were reported for the year 1995 for Hartz Bleachers. Forms 1099-MISC totaling $153,712 were issued to Hartz Bleachers for the year 1995. Respondent determined that the amount reported on the Forms 1099-MISC accurately reflected gross income for Hartz Bleachers for * * * 1995. Gross receipts of [$189,159] were reported for the year 1996 for Hartz Bleachers. Forms 1099-MISC totaling $187,809 were issued to Hartz Bleachers for the year 1996. Books kept for Hartz Bleachers reported receipts of $227,800. Bank deposits into accounts held by petitioners and Hartz Bleachers for the year 1996 totaled $239,234. Respondent determined that the correct amount of income was [$227,800], as shown on petitioners’ books and records. * * * * * * * For the year 1996, [$13,595] of the amount allowed by respondent as a deduction for compensation [see discussion infra] was for amounts Hartz Bleachers paid to petitioner Shari L. Hartz. Respondent also determined that this amount should be reported as income by Shari L. Hartz for * * * 1996. No party presented reliable evidence concerning the correct amount of wage and business income in 1995 and 1996. Although petitioner testified briefly concerning the business income, the extent of his testimony was that he relied upon the Forms 1099 in calculating the total amount of income in each year. The FormsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011