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incorporated herein by this reference. In addition, petitioner
offered oral testimony and other separate exhibits which are
irrelevant to the question of whether respondent’s determinations
should be sustained.
At the time the petition was filed, petitioner resided in
Jamaica, New York.
Petitioner failed to file a Federal income tax return for
the tax year 2000. As a result, respondent issued to petitioner
the notice of deficiency for the tax year 2000 upon which this
case is based. Nevertheless, the parties have stipulated that
petitioner was required to report gross income for the year 2000,
under section 61, in the form of royalties from the sources and
in the amounts that follow:
Source Amount
Broadcast Music, Inc. $3,385
Warner Music Group 2,219
Thump Records, Inc. 407
Warner Chappell, Inc. 16,113
In addition, the parties have stipulated that the additions to
tax under sections 6651(a)(1) and 6654(a) are applicable to
petitioner’s 2000 tax liability.
Petitioner believes that the Form 1099 he received from
Warner Chappell for the year 2000 is false and fraudulent and
that he should have received royalties in excess of the $16,113
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Last modified: May 25, 2011