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Respondent determined a deficiency in petitioner’s Federal
income tax of $3,210 for the taxable year 1999. The sole issue
for decision is whether an $8,000 payment petitioner received in
1999 is includable in petitioner’s gross income.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Morrisville, North Carolina, on the date the petition was filed
in this case.
From 1992 through July 1998, petitioner was employed by the
National Society of Black Engineers (NSBE) of Alexandria,
Virginia. Petitioner was a corporate fund-raiser and handled
national convention career fairs for NSBE. Throughout his
employment with NSBE, petitioner was enrolled at Howard
University earning an undergraduate degree in engineering.
Petitioner finished his degree shortly after leaving NSBE.
Petitioner had a verbal agreement with NSBE that he would be
reimbursed for certain educational expenses he incurred at
Howard. NSBE later instituted a formal tuition assistance
program, but petitioner was not a participant in this program.
In discussions with employees of NSBE, petitioner was told that
they were “not able to find an exact document that details” such
an agreement. Although admitting that petitioner was to be
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