- 4 - In early 1999, there was issued to petitioner on behalf of Champion a Form W-2, Wage and Tax Statement (W-2), reflecting that during 1998 Champion had paid wages to petitioner in the total amount of $129,541. Petitioner’s 1998 individual Federal income tax return was not timely filed. Champion’s 1998 corporate Federal income tax return was timely filed with respondent. On that corporate tax return, the full $129,541 reflected as wages paid to petitioner on the above W-2, including the $95,233 amount of check No. 1546, was reflected as a wage expense deduction of Champion. On November 5, 2001, pursuant to an audit and respondent’s preparation of a substitute 1998 tax return for petitioner, respondent mailed to petitioner a notice of deficiency for 1998 in which respondent determined, among other things, that the $95,233 face amount of check No. 1546 constituted taxable wage income to petitioner in 1998. Respondent also determined that the additional $34,308 reflected on the W-2 issued to petitioner constituted taxable wage income to petitioner in 1998. In September 2002, petitioner hired a certified public accountant to review petitioner’s and Champion’s books and records and to prepare tax returns on behalf of petitioner and Champion.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011