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and unemployment compensation from the State of Arizona of
$3,485.
Tax Return and Notice of Deficiency
Petitioner timely filed a Form 1040, U.S. Individual Income
Tax Return, for 2001. A copy of the return was not made part of
this record, but the parties did attach a copy of a RTVUE, which
is a type of Internal Revenue Service electronic transcript
reflecting relevant information from the 2001 return.2
Petitioner did not report, on the 2001 return, the $3,485 of
unemployment compensation received from the State of Arizona.
Petitioner also claimed an IRA deduction in the amount of $2,000.
In an amended return, Form 1040X (stamped received by the IRS on
April 29, 2004), petitioner attached a Schedule C wherein she
reported gross receipts of zero and claimed expenses of $5,302.
In the notice of deficiency, respondent determined that
petitioner received unreported unemployment compensation income
of $3,485. Respondent further disallowed the claimed IRA
deduction.3
2 The Court notes that the RTVUE reflects wages of $17,808.
The stipulation of facts reflects wages of $15,808. The record
does not explain this discrepancy. The Court’s findings are
premised on the stipulation of facts.
3 The Schedule C, Profit or Loss From Business, deduction
of $5,302 was not claimed by petitioner until after the notice of
deficiency was issued and after the petition was filed.
Accordingly, the claimed deduction is considered by the Court as
if properly raised by amendment to petition.
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Last modified: May 25, 2011