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either cashed or deposited into an unidentified account.
Unwrapped issued a Form 1099-MISC, Miscellaneous Income, to
“Liberty Temp.-D/B/Andrew Chook” for 2002, reporting nonemployee
compensation of $447,084.
Petitioner timely filed a Federal income tax return for
2002. Petitioner reported total income of $14,400, total tax of
zero, total payments of $4,055, and requested a refund of $4,055.
Petitioner did not report the money received from Unwrapped, nor
did he claim any deductions related to the operation of Liberty
Temp.
On December 6, 2004, respondent issued petitioner a notice
of deficiency for 2002. Based on information reported by
Unwrapped, respondent determined that petitioner received but
failed to report income of $447,084 from nonemployee
compensation. Respondent determined a deficiency in petitioner’s
2002 Federal income tax of $171,823 and an accuracy-related
penalty under section 6662(a) of $34,365.
In response to the notice of deficiency, petitioner filed a
petition with this Court on March 7, 2005.
Despite the requirements of the United States Tax Court’s
Rules of Practice and Procedure, the Court’s standing pretrial
order,4 and respondent’s repeated attempts to meet with
4 The standing pretrial order, along with the notice
setting case for trial, was filed on Oct. 6, 2005. The standing
(continued...)
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