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The issues for decision are: (1) Whether $57,845 petitioner
received in 2001 from an American Indian tribe constitutes
taxable income to petitioner; (2) whether $33,295 of the $57,845
petitioner received constitutes self-employment income on which
petitioner is liable for Federal self-employment tax; and
(3) whether petitioner is liable for the section 6662(a)
accuracy-related penalty for substantial understatement of income
and self-employment tax.
Unless otherwise indicated, 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.
FINDINGS OF FACT
Under Rule 91(f)(3), some of the facts have been deemed
stipulated and are so found.1
At the time the petition was filed, petitioner was a
resident of Lac du Flambeau, Wisconsin.
1 On Aug. 31, 2004, respondent filed a Rule 91(f) motion
with regard to proposed stipulated facts. On Sept. 3, 2004, the
Court issued an order granting respondent’s Rule 91(f) motion and
directing petitioner to file a response to the motion by Oct. 4,
2004. Petitioner failed to respond to respondent’s Rule 91(f)
motion, and on Oct. 13, 2004, the Court made absolute its Sept. 3,
2004, order, and the facts set forth in the proposed stipulation
of facts were deemed stipulated, and the exhibits were admitted
for purposes of trial and opinion herein.
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