- 4 - 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 issuesPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011