- 5 -
for his work during 1997 on the Enterprise and the Elizabeth R.,
respectively.
Petitioner did not receive health insurance benefits4 or any
other payments from the boat owners on account of his fishing
activities during 1997.
On Schedule C, Profit or Loss From Business, of their 1997
Federal income tax return, petitioners reported gross income of
$50,486 from petitioner’s fishing activities and claimed no
expenses as deductions. On Schedule A, Itemized Deductions, of
their 1997 return, petitioners claimed unreimbursed employee
business expenses of $4,438 and gross medical expenses of $7,137,
which included health insurance premiums of $5,077. Petitioners
did not pay their reported 1997 income tax liability of $3,491.
Petitioners also failed to report or pay self-employment tax on
petitioner’s fishing activities.
On May 10, 1999, petitioners filed Form 1040X, Amended U.S.
Individual Income Tax Return, for 1997, reporting no income tax
liability for income petitioner received from his fishing
activities.5
4We interpret this inartfully drafted stipulation to mean
that neither the boat owners nor the corporations paid petitioner
any additional amount to fund his payments of health insurance
premiums.
5Petitioners were the petitioners in Anderson v.
Commissioner, T.C. Memo. 2003-112, a case under sec. 6330
concerning their failure to pay Federal income tax reported on
(continued...)
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