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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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