James E. Anderson and Cheryl J. Latos - Page 5

                                        - 5 -                                         
          for his work during 1997 on the Enterprise and the Elizabeth R.,            
               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                   

               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              
               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              

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011