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Respondent determined a deficiency of $2,508 in petitioners'
Federal income tax for 1999.
The sole issue for decision is whether Louis Bonner, Jr.
(petitioner) received payments during 1999 that constitute gross
income under section 61(a)(1) as compensation for services
rendered.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are incorporated
herein by reference. Petitioners, husband and wife, were
residents of Shreveport, Louisiana, at the time the petition was
filed.
Petitioner is a cabinet maker, building such things as
kitchen cabinets, bookcases, and shelves. He has been engaged in
this kind of work for approximately 30 years. Petitioner Celeste
Bonner was employed by Century Telephone Co. during the year in
question in the collections department. At trial, she was
employed by Alltell Telephone Co.
Petitioners filed a joint Federal income tax return for 1999
on which they reported wage and salary income of $37,314, taxable
interest income of $13, and taxable pension income of $755, all
of which totaled $38,082. In their tax computation, petitioners
included the 10-percent tax under section 72(t) for early
distributions from a qualified plan in the amount of $76.
Respondent determined that petitioners failed to include on their
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