- 4 - he was paid by Warner Chappell for that year. Nonetheless, he stipulates that he did receive the $16,113. Discussion Petitioner’s position in this case is based upon the erroneous impression that he should not have to pay income tax on his 2000 royalty income until respondent forces Warner Chappell to admit petitioner is owed additional royalties for that year or at least until respondent investigates Warner Chappell. Petitioner is misinformed as to respondent’s obligation and as to the authority of this Court. As the Court attempted to explain to petitioner at trial, this case is solely about determining his correct tax liability for the year 2000 since the additions to tax have been resolved. Petitioner’s claim for increased royalties from Warner Chappell has no bearing on the matters before this Court. As in a prior case before this Court, petitioner has not offered any evidence on the matter that we can properly adjudicate. See Poindexter v. Commissioner, 122 T.C. 280 (2004). Accordingly, with the exception of respondent’s concession of the addition to tax under section 6651(a)(2), respondent’s position is sustained, and An appropriate decision will be entered.Page: Previous 1 2 3 4
Last modified: May 25, 2011