- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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