Estate of Nicholas Charles Stevens, Jr., Deceased, Kim Patricia Bryan, Personal Representative - Page 3

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               Respondent determined a deficiency in decedent’s Federal               
          income tax of $1,324 and an addition to tax under section                   
          6651(a)(1) of $121 for taxable year 2000.  After respondent’s               
          concession,1 the issue for decision is whether decedent is                  
          taxable on unreported income of $12,154 from wages and interest             
          during the 2000 taxable year.                                               
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated herein by this reference.                                      
               Nicholas Charles Stevens, Jr. (decedent) died in Baltimore             
          County, Maryland, in October 2001 at the age of 18 years.                   
          Decedent’s mother, Kim Patricia Bryan (Ms. Bryan), was directed             
          to serve as personal representative of decedent’s estate.  At the           
          time the petition was filed, Ms. Bryan resided in Baltimore,                
          Maryland.                                                                   
               During the year in issue, decedent received wages of $1,048            
          from Maryland Car Care, Inc. and $4,719 from Mangione Enterprises           
          of Turf Valley.  Also during the year in issue, decedent was                
          credited with interest income of $7,435 from custodial accounts             
          at Farmers and Mechanics National Bank.  Such accounts were                 
          established pursuant to the Maryland Uniform Transfers to Minors            


               1  Respondent concedes that decedent is not liable for the             
          addition to tax under sec. 6651(a)(1) of $121.                              





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