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reference. At the time of filing the petition, petitioner
resided in Los Angeles, California.
Background
Petitioner did not file a Federal income tax return for
1997.2 On November 1, 2001, respondent issued to petitioner a
notice of deficiency in which respondent determined a deficiency
and additions to tax for petitioner’s 1997 tax year.
Respondent’s determination was based on information returns
received from third-party payors. The following amounts were
reported as paid to petitioner in 1997:
Payor Type of Payment Amount Paid
Compton Unified
School District Wages $27,325
Merrill Lynch et al. Stocks/bonds sale 2
Merrill Lynch et al. Stocks/bonds sale 17
Merrill Lynch et al. Stocks/bonds sale 19
Merrill Lynch et al. Stocks/bonds sale 401
Merrill Lynch et al. Stocks/bonds sale 694
Merrill Lynch et al. Dividends (ordinary) 22
Wells Fargo Bank Interest 16
American Network NEC income (nonemployee
Ins. Co. compensation) 31
Mitchell Energy Corp. Royalties 7,220
R.W. Durham NEC income (nonemployee
compensation) 1,427
Petitioner does not dispute receiving the payments reflected
above. With respect to the various proceeds from stock and bonds
sales reported by Merrill Lynch, Pierce, Fenner & Smith, Inc.,
2 Petitioner mailed to respondent a Federal income tax
return for 1997 on May 18, 2004, one day before the date of his
trial. A copy of the return was admitted at trial solely for the
purpose of assisting petitioner in developing his arguments and
claims for various deductions.
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