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During 1994, Sportland Properties, Inc. (Sportland Proper-
ties) paid wages totaling $6,227 to petitioner.
During 1994, the Bank of Ocean City (Ocean City Bank) paid
interest totaling $140 to petitioner.
The State of Maryland reported to respondent in Form W-2,
Wage and Tax Statement (Form W-2), for 1994 that it paid to
petitioner during that year wages totaling $194,170 (i.e., the
$170,000 settlement and other wages totaling $24,170).
Sportland Properties reported to respondent in Form W-2 for
1994 that it paid to petitioner during that year wages totaling
$6,227.
Ocean City Bank reported to respondent in Form 1099-INT,
Interest Income, for 1994 that it paid to petitioner during that
year interest totaling $140.
Petitioner did not make any estimated tax payments with
respect to her taxable year 1994. Nor did petitioner file Form
1040, U.S. Individual Income Tax Return (tax return), for that
year.3
Respondent issued a notice of deficiency (notice) to peti-
tioner for her taxable year 1994. In that notice, respondent
determined that petitioner has total unreported income of
$200,537 for 1994 consisting of wages totaling $194,170 that the
3Respondent has no record that petitioner filed a tax return
for her taxable year 1994.
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