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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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