Glory Allen - Page 2

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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              

                                  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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