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withheld from these amounts. Similarly, during 2001, petitioner
received $31,779 in nonemployee compensation from GCE for which a
Form 1099-MISC was issued and from which no Federal income tax
was withheld.
Petitioner did not file Federal income tax returns for the
years 1999, 2000, and 2001. On January 22, 2003, respondent
issued to petitioner a notice of deficiency with respect to 1999,
and on August 8, 2003, respondent likewise issued to petitioner a
separate notice of deficiency for each of the years 2000 and
2001. Therein respondent determined the deficiencies and
additions to tax referenced above. The deficiencies were based
solely on the compensation paid to petitioner by GCE.
Petitioner’s petitions disputing these determinations,
having been postmarked timely, were filed with the Court on
April 28, 2003, as to 1999, and on November 10, 2003, as to 2000
and 2001. The petitions are substantially identical, each
asserting that petitioner “did not receive any taxable income
from any taxable source” during the subject years and that, even
if income can be attributed to him, he “would still be entitled
to the deductions, allowances and credits that the examining
Revenue Officer failed to even request from the Petitioner.”
Petitioner then prays that the Court dismiss the notices of
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