Alex B. Rhodes, Jr. - Page 3

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                                    FINDINGS OF FACT                                     
               Some of the facts have been stipulated and are so found.                  
               At the time the petition was filed, petitioner resided in                 
          Plano, Texas.                                                                  
               During 1998 and 1999, petitioner resided in Texas and                     
          received wage income for employment with various companies as an               
          information systems consultant, a technical computer consultant,               
          and an “internetwork” engineer.  Petitioner also earned                        
          investment income.                                                             
               For 1998 and 1999 respectively, petitioner earned income                  
          from both wages and investments in the total amounts of $110,138               
          and $110,826.  In 1998 and 1999, petitioner submitted to his                   
          employers Forms W-4, Employee’s Withholding Allowance                          
          Certificate, on which petitioner claimed to be “Exempt” from                   
          Federal income tax.  As a result, for 1998 no Federal income tax               
          was withheld from petitioner’s wages, and for 1999 only $354 was               
          withheld.                                                                      
               During 1998 and 1999 respectively, petitioner incurred                    
          employee business expenses in the amounts of $4,629 and $4,725.                
          Although available to him, petitioner did not request                          
          reimbursement of these expenses from his employers.                            
               For 1997, 1998, and 1999, petitioner did not file Federal                 
          income tax returns.  Other than the above $354 withheld from                   








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