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On the record before us, we find that petitioner is required
to include the entire amount of the $170,000 settlement in her
gross income for her taxable year 1994.
Other Income
The parties stipulated that, in addition to the $170,000
settlement that the State of Maryland paid to petitioner during
1994, during that year: (1) The State of Maryland also paid her
wages totaling $24,170; (2) Sportland Properties paid her wages
totaling $6,227; and (3) Ocean City Bank paid her interest
totaling $140. Petitioner advances no argument as to why such
wages and interest should be excluded from her gross income for
1994.
On the record before us, we find that petitioner is required
to include in her gross income for her taxable year 1994 the
additional wages totaling $24,170 that the State of Maryland paid
to her, the wages totaling $6,227 that Sportland Properties paid
to her, and the interest totaling $140 that Ocean City Bank paid
to her.
Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a tax return on the date prescribed for filing, unless the
taxpayer proves that such failure to file was due to reasonable
cause and not willful neglect.
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