Deborah A. Messina - Page 13

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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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