Stephen Jones - Page 1

                                 T.C. Memo. 2003-14                                   

                               UNITED STATES TAX COURT                                

                            STEPHEN JONES, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2970-01.              Filed January 14, 2003.               

               Kenneth W. McWade, for petitioner.                                     
               Jonathan J. Ono, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  Respondent determined a $17,052 deficiency             
          in petitioner’s income tax for 1997.                                        
               The sole issue for decision is whether petitioner may                  
          exclude from gross income under either section 931 or section 911           
          compensation he earned for personal services he performed in 1997           

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