- 4 - the Company had paid petitioner in 2001 the above $148,744 as nonemployee compensation. On April 3, 2002, petitioners signed and filed with respondent their 2001 joint Federal income tax return on which petitioners reported no income and no legal fees with respect to petitioner’s employment discrimination lawsuit and the arbitration award. On October 6, 2003, respondent mailed to petitioners a 30- day letter proposing to include in petitioners’ income for 2001 the $148,744 reflected by the payments made by the Company in 2001 on the arbitration award. Also, in the 30-day letter, respondent, apparently for lack of substantiation, proposed to deny petitioners any deduction for legal fees relating to the arbitration award. On February 2, 2004, respondent mailed to petitioners a notice of deficiency in which respondent treated as petitioner’s “other income,” not as Schedule C income, the $148,744 the Company paid in 2001 on the arbitration award and in which respondent, for apparent lack of substantiation, did not allow any deduction for legal fees relating to the arbitration award. On February 3, 2004, petitioners signed and filed with respondent an amended joint Federal income tax return for 2001 on which petitioners reported as income on a Schedule C the $148,744Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011