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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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