Tony J. Cavender - Page 2

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               All section references are to the Internal Revenue Code in             
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  
               After concessions, the primary issue for decision is whether           
          petitioner received additional wage income in the amount of                 
          $102,126.                                                                   
                                  FINDINGS OF FACT                                    
               Some facts are stipulated and are so found.                            
               At the time the petition was filed, petitioner resided in              
          Fairview, Tennessee.  Petitioner’s filing status for 1998 was               
          “married filing separate”.                                                  
               In May 1998, petitioner incorporated under Tennessee law               
          Champion Home Centers, Inc. (Champion), to sell modular homes.              
          Throughout 1998, petitioner was an employee of and was the sole             
          shareholder in Champion.  Although the record in this case does             
          not disclose petitioner’s particular title as an employee of                
          Champion, petitioner was in control of Champion.                            
               In the fall of 1998, petitioner hired a part-time bookkeeper           
          to work for Champion.  The bookkeeper worked 10 hours a week for            
          approximately 5 months.                                                     
               On December 30, 1998, a check in the amount of $95,233 was             
          drawn on Champion’s checking account at Franklin National Bank.             
          The check was made payable to petitioner and stated on its face             
          that it related to “Payroll 12-31-98”.  The check was made out by           






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