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income from 1998 through 2003.1 For the past several years,
petitioner has been a student at City College of San Francisco
(City College). At the time of trial, petitioner was a senior at
City College but was unsure when he would graduate. Petitioner
indicated that City College had recently reduced its offering of
courses due to budget constraints, which has delayed his
graduation. Petitioner has maintained himself during this time
by using student loan proceeds and by minimizing his living
expenses.
In the taxable year 2002, petitioner won a car from Centra
Marketing & Communications, LLC (Centra) as part of an Internet
sales promotion. Petitioner sold the car shortly after receiving
it, although it is not clear what he did with the proceeds.
Centra issued a Form 1099-MISC, Miscellaneous Income, to
petitioner reflecting $38,540 of gross income attributable to the
car. Petitioner reported that amount on his 2002 Federal income
tax return, as well as $146 of interest income, but made no
payments toward his tax liability.
Respondent made assessments against petitioner for the
taxable year 2002 totaling $5,942.01 for income tax and related
penalties and interest. In July 2004, respondent filed a notice
of Federal tax lien and sent petitioner a Notice of Federal Tax
1 The record does not indicate whether petitioner had other
sources of income during these years, other than a small amount
of interest income that he received in the taxable year 2002.
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