Tony J. Cavender - Page 5

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               In December 2002, shortly before trial herein, there was               
          issued to petitioner on behalf of Champion a Form W-2c, Corrected           
          Wage and Tax Statement for 1998.  At the same time, there was               
          filed with respondent on behalf of Champion a Form W-3c,                    
          Transmittal of Corrected Wage and Tax Statements for 1998.  Both            
          statements reflected that, during 1998, Champion had paid wages             
          to petitioner in the total amount of only $27,415.                          
               On December 27, 2002, petitioner filed with respondent his             
          original 1998 individual Federal income tax return, which the               
          accountant had prepared.  On that return, petitioner reported               
          total wages received in 1998 from Champion of only $27,415.                 
               Also on December 27, 2002, there was filed with respondent             
          on behalf of Champion an amended 1998 corporate Federal income              
          tax return for 1998, reflecting a $102,126 decrease in the                  
          deduction claimed for wages paid to petitioner.1                            

                                       OPINION                                        
          Taxable Wage Income                                                         
               Section 61(a) defines gross income as “all income from                 
          whatever source derived,” including compensation for services.              
          The Supreme Court has held that gross income includes “undeniable           
          accessions to wealth, clearly realized, and over which the                  


               1 $129,541 (wage deduction claimed on Champion’s original              
          1998 corporate Federal income tax return) less $27,415 (wage                
          deduction claimed on Champion’s amended 1998 corporate Federal              
          income tax return) equals $102,126.                                         




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