Robert E. Rhodes - Page 4

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          III. 2000                                                                   
               During 2000, petitioner worked for AIC.  AIC issued                    
          petitioner a Form W-2 for 2000 reflecting wages of $46,754.84 and           
          zero Federal income tax withheld.  Petitioner received $13 of               
          interest in 2000.  Arlington Federal Credit Union (AFCU) issued             
          petitioner a Form 1099-INT, Interest Income, for 2000 reflecting            
          this interest.                                                              
          IV. 2001                                                                    
               During 2001, petitioner worked for AIC.  AIC issued                    
          petitioner a Form W-2 for 2001 reflecting wages of $46,465 and              
          zero Federal income tax was withheld.  Petitioner received a $4             
          ordinary dividend in 2001.  Datek Online Holdings Corp. issued              
          petitioner a Form 1099-DIV, Dividends and Distribution, for 2001            
          reflecting this dividend.  Petitioner received $11 of interest in           
          2001.  AFCU issued petitioner a Form 1099-INT for 2001 reflecting           
          this interest.                                                              
                                       OPINION                                        
          I.   The Deficiency                                                         
               As a general rule, the taxpayer bears the burden of proving            
          the Commissioner’s deficiency determinations incorrect.  Rule               
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).  Section              
          7491(a), however, provides that if a taxpayer introduces credible           
          evidence and meets certain other prerequisites, the Commissioner            
          shall bear the burden of proof with respect to factual issues               






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