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(b) For 1988, petitioner documented $5,113.77 of payments to
the IRS ($4,034.98) and the Minnesota Department of Revenue
($850.90) and deposits into petitioner’s payroll account
($227.89) covering the months of February, May, July, August, and
October 1988 (Ex. 39-R, lines 652-664). Of the amounts
documented, petitioner concedes that $1,200.97 was deposited into
the payroll account (and presumably was claimed as a wage
deduction), and respondent concedes the deductibility of the
payments to the Minnesota Department of Revenue.
(c) For 1989, petitioner documented $3,068.20 of payments to
the IRS ($2,324.64) and to the Minnesota Department of Revenue,
the Minnesota Department of Jobs, the Minnesota UC Fund, the
Commissioner of Revenue, and the Employee Benefit Administration
($743.56) (Ex. 40-R, lines 257-266). Respondent conceded the
deductibility of all of these payments.
(d) For 1990, petitioner documented $11,253.01 of payments
to the IRS ($9,888.44), the Department of Revenue ($1,167.19),
and the Minnesota Department of Jobs ($197.38) (Ex. 41-R, lines
809-838) but provided no information regarding the nature or
purpose of the payments. Respondent has not conceded that any of
these payments is deductible.
(e) During each of the years at issue, petitioner paid wages
to employees and had an obligation to pay the employer’s share of
Federal Insurance Contributions Act (FICA) and Federal
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