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determined petitioner was liable for a $1,900.60 accuracy-related
penalty under section 6662. For 2001, respondent determined a
deficiency of $20,812.00 and determined petitioner was liable for
a $4,162.40 accuracy-related penalty under section 6662.
There are four issues for decision. The first issue is
whether compensation petitioner received from an American Indian
tribe during the years at issue is taxable to him. We hold that
it is. The second issue is whether petitioner may reduce his
income by $69,916 for 2001. We hold that he may not. The third
issue is whether petitioner is entitled to deductions beyond
those reported on his returns for the years at issue. We hold
that he is not. The fourth issue is whether petitioner is liable
for the accuracy-related penalty under section 6662 for the years
at issue. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioner resided in Lac Du
Flambeau, Wisconsin, at the time he filed the petition.
Petitioner’s Income During the Years at Issue
Petitioner is an enrolled member of the Lac Du Flambeau
Band, a federally recognized American Indian tribe (the tribe).
The leadership of the tribe consists of an elected tribal
council. Petitioner served as vice chairman of the tribal
1(...continued)
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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