Chay R. Stewart - Page 3

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                                                            Type of                   
          Payor                    2000        2001         payment                   
          Midland Natl. Life       $129,829   $221,795      commissions               
          Ins. Co.                                                                    
          Lifeusa Ins. Co.         17,812                   commissions               
          Financial Brokerage,     8,646      3,008         commissions               
          Inc.                                                                        
          Fidelity & Guaranty                     1,050     commissions               
          Life Ins.                                                                   
          American Equity Inv.                    6,017     commissions               
          Life Ins                                                                    
          Charles Schwab & Co.          541       96        interest                  
          Commercial Bank of                                                          
          Volusia County           682        481           interest                  
                                   $157,510   $232,447                                
               Petitioner filed no Federal income tax returns and made no             
          estimated tax payments for 2000 and 2001.  No Federal income tax            
          was withheld from his income for 2000 and 2001.                             
          B.   Respondent’s Determination                                             
               In the notice of deficiency, respondent determined that                
          petitioner had received but failed to report self-employment                
          income from commissions in the amounts of $156,287 in 2000 and              
          $231,870 in 2001 and interest income in the amounts of $1,223 in            
          2000 and $577 in 2001.  Respondent determined that petitioner’s             
          filing status was single and that he was entitled to claim the              
          standard deduction and one exemption.  Respondent determined that           
          petitioner was liable for additions to tax for failure to file              








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