Cindee J. Conner - Page 8




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          2.  Unreported Wage Income                                                  
               As previously stated, respondent determined that petitioner            
          did not file a Federal income tax return for the taxable year               
          1997, and did not report wage income of $33,711 received during             
          that year.  Petitioner, however, contends that her husband                  
          purportedly filed a joint return “on their behalf” in 1997, and             
          that the wage income at issue was reported on that return.                  
          Therefore, she argues, she has no present liability for tax                 
          stemming from her unreported wage income received in 1997.                  
               Section 61(a) defines gross income as “all income from                 
          whatever source derived, including * * * (1) Compensation for               
          services” unless otherwise provided.  Moreover, section 6001                
          requires any person liable for tax imposed under title 26 to keep           
          records, render statements, make returns, and comply with the               
          rules and regulations.                                                      
               In this case, petitioner admitted at trial that she did, in            
          fact, receive wage income in 1997 in the amount of $33,711, from            
          her work as a dance instructor.  However, she also testified that           
          she kept no records of receiving these wages and filed no                   
          separate return for that year.  Petitioner nevertheless contests            
          respondent’s determination of her liability on the grounds that             
          she and Mr. Conner had agreed to file a joint return for 1997 to            
          include this income, and that irrespective of whether or not a              
          joint return was filed, she could not have filed separately for             







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