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Penalty
Year Deficiency Sec. 6662(a)
1997 $7,702 $363.00
1999 6,671 43.60
2000 4,926 58.40
Following concessions,2 the issues remaining for decision
are: (1) Whether $23,480, $22,450, and $13,550 received by
petitioner Mary Doxtator (Mrs. Doxtator) in 1997, 1999, and 2000,
respectively, from the Oneida Tribe of Indians of Wisconsin
(Oneida Tribe or Tribe) for services as a judicial officer are
subject to income tax and self-employment tax; (2) whether
petitioner Allen Doxtator (Mr. Doxtator) was engaged in a trade
or business in 1997 and 2000, entitling petitioners to cost of
goods sold of $225 in 1997 and trade or business deductions of
$7,580 and $7,748 for 1997 and 2000, respectively; (3) whether
petitioners received short-term capital gain of $1,000 and long-
term capital gain of $146 in 1999; (4) whether petitioners
received taxable dividends of $281 in 1999; (5) whether $3,000
petitioners received from the Oneida Tribe in 1999 is taxable;
(6) whether petitioners are entitled to charitable contribution
deductions of $5,899 and $3,969 in 1997 and 2000, respectively;
(7) whether petitioners are entitled to a casualty loss in 2000
2 Respondent conceded $1,090 of the $4,516 casualty loss
petitioners claimed in 2000. Petitioners conceded taxable
interest income of $64 and $121 for 1999 and 2000, respectively,
at trial.
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Last modified: May 25, 2011