Daniel E. Spurlock - Page 3

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               Petitioner is a professional musician.  During the years at            
          issue, he was employed as a double bassist with the Louisville              
          Orchestra and served as music director of the Louisville Chorus             
          and of the Beargrass Christian Church.  In 1994, 1997, and 1998,            
          petitioner also performed services for Commonwealth Musicians, a            
          musical booking agency.  As of December 31, 1998, petitioner had            
          not reached age 59 and one-half.                                            
               For each year at issue, petitioner filed no Federal income             
          tax return and made no estimated tax payments.  Respondent                  
          commenced his examination after July 22, 1998.  In the notice of            
          deficiency, respondent determined that petitioner had unreported            
          taxable income in the following amounts:                                    
               Beargrass                                                              
               Christian           Louisville            Commonwealth                 
          Year     Church              Orchestra               Musicians              
          (Employee)     (Employee) (Self-Employed) (Self-Employed)                   
          1994    $16,417     $32,878        --                  --                   
          1995     17,067        33,167      $3,500              --                   
          1996     19,416        29,744      17,000              --                   
          1997     21,771        31,013        4,000          $1,738                  
          1998     22,817         1,758      --             --                        
               In addition, respondent determined in the notice of                    
          deficiency that petitioner received premature individual                    
          retirement account (IRA) distributions of $9,122 and $16,576 in             
          1995 and 1997, respectively, that were includable in petitioner’s           
          taxable income and that were also subject to a 10-percent                   
          additional tax pursuant to section 72(t).                                   







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