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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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Last modified: May 25, 2011