Thomas R. Jones - Page 6

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          petitioner, but it is not clear whether petitioner received a               
          copy of this Form 1099.                                                     
               Also for 2000, UCLI submitted to respondent a Wage and Tax             
          Statement, Form W-2, Wage and Tax Statement, with regard to the             
          $22,230 paid to petitioner, and petitioner received a copy of               
          this W-2.                                                                   
               Without consulting a tax professional and apparently under             
          the impression that the disability benefits he received in 2000             
          did not constitute taxable income, petitioner did not file a                
          Federal income tax return for 2000.                                         
               On his 2000 individual Federal income tax return, Peterson             
          claimed an interest deduction in the amount of the total monthly            
          mortgage payments that were made on the property in 2000.                   
               In May of 2002, petitioner obtained a $100,000 mortgage on             
          the property, and Peterson’s mortgage was paid off.  Petitioner             
          exercised the option to purchase the property and paid Peterson             
          the required $5,000 exercise price.  The legal title to the                 
          property was then transferred from Peterson to petitioner.                  
               Upon audit, respondent determined that petitioner’s 1999               
          Federal income tax liability was $13,236.  Petitioner remitted              
          this amount to respondent plus penalties and interest.                      
               At respondent’s request, on October 9, 2002, petitioner                
          filed his 2000 individual Federal income tax return, upon which             
          he reported zero taxable income.                                            






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