- 30 - Hofflund Polone, a partnership, allocated to petitioner or petitioner’s wholly owned corporation the following taxable income: $84,416 in 1996, $1,300,423 in 1997, $1,624,867 in 1998, $1,684,024 in 1999, $2,395,145 in 2000, and $2,377,146 in 2001. On or about October 10, 1997, petitioner filed his 1996 Federal income tax return. Petitioner did not include the May 1996 payment in income on his 1996 return. Petitioner reported, under other income on his 1996 return, a $1 million payment from UTA on his 1996 return. This amount, which represented the November 1996 payment, was in addition to the wages he reported from UTA in 1996. Statement 1 of petitioner’s 1996 return stated: “Taxpayer received $1 million from United Talent Agency (UTA), representing settlement of claims by taxpayer for personal injury against UTA, pursuant to an agreement as of May 1, 1996. The lump-sum payment received does not constitute income subject to self-employment tax.” On his 1997 return, petitioner reported, under other income, $2,000. Petitioner did not include the May 1997 payment in income. On the line for other income “See Statement 1" was typed in. Statement 1 of petitioner’s 1997 return listed $2,000 from Conde Nast Publications and $1 million from UTA as “miscellaneous income” and subtracted out $1 million as UTA settlement proceeds to arrive at a total of $2,000. Below the subtraction were the words “see footnote”. The footnote, contained in statement 2, stated:Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011