Vittorio Kellum - Page 6

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          respondent’s reasonable requests.  For similar reasons, section             
          6201(d) does not apply to place on respondent the burden of                 
          producing evidence to supplement the information returns.  See              
          McQuatters v. Commissioner, T.C. Memo. 1998-88.                             
          A.  Income From Compton Unified                                             
               Petitioner began working as a math and science teacher for             
          Compton Unified in September 1995.  Sometime about February 15,             
          1996, petitioner was injured during an altercation with a student           
          while teaching at Whaley Middle School.  Petitioner suffered a              
          back injury and was unable to teach his classes for the remainder           
          of the spring 1996 school term.  Petitioner was granted                     
          “industrial accident leave” from February 16 until June 12, 1996,           
          and continued to receive his full salary.                                   
               Petitioner returned to teaching in September 1996 for the              
          beginning of the 1996-97 school year.  Due to continuing concerns           
          over his health, petitioner returned as a substitute teacher on a           
          temporary contract and was assigned to the district’s substitute            
          pool.  Certified quarterly earnings reports prepared by Compton             
          Unified reflect that petitioner received a monthly salary of                
          $2,626.81 from January 1997 through June 1997 and $2,895.77 for             
          September 1997 through December 1997.4  Compton Unified’s                   

               4  No Federal income taxes were withheld from petitioner’s             
          salary during this time.  Compton Unified’s payroll administrator           
          testified that petitioner was classified as an “exempt                      
          individual”, but did not further explain the basis for the                  
                                                             (continued...)           





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