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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.
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Last modified: May 25, 2011