Raymond J. Davis - Page 3

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               Respondent determined deficiencies in petitioner's Federal             
          income taxes of $2,526 for 1999 and $3,819 for 2000.  The issues            
          for decision are whether petitioner, for both years, properly               
          reported pension income and is entitled to claim trade or                   
          business expense deductions.  Respondent's adjustments to                   
          petitioner's itemized deductions and the taxable amount of his              
          Social Security benefits are computational and will be determined           
          by the Court's resolution of the income and expense issues.                 
               The stipulated facts and exhibits received into evidence are           
          incorporated herein by reference.  At the time the petition in              
          this case was filed, petitioner resided in Sacramento,                      
          California.                                                                 
                                     Background                                       
               There is no disagreement among the parties as to the facts             
          in this case, which are almost fully stipulated.  Before his                
          retirement in 1990, petitioner was self-employed as an                      
          independent insurance agent for the New York Life Insurance                 
          Company (company).  After a surgery, petitioner retired on                  
          disability due to heart-related health problems.  Upon his                  
          retirement, the company transferred his clients to another                  
          insurance agent and began paying pension distributions to                   
          petitioner.  There is no indication that there was any                      
          understanding that he would return to his position as an agent              
          for the company.                                                            






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