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amount of $30,811.50, comprising real estate sales commissions in
connection with his association with Oregon First. Under an
expense reimbursement agreement with Oregon First, $17.51 of
office expenses was deducted from the real estate commissions
that petitioner received from Oregon First during 2002 so that he
received net commissions of $30,793.99.
During 2002, petitioner was also employed as a loan officer
by Columbia Resources, Inc. (Columbia), of Warrenton, Oregon.
Petitioner received $3,371.382 in wages from Columbia for the
2002 taxable year, from which $294.00 of income tax was withheld.
Petitioner did not make estimated tax payments for the 2002
tax year, and he failed to file a Federal income tax return for
that year. Respondent prepared a substitute return for
petitioner’s 2002 tax year under section 6020(b).
Respondent concedes that petitioner incurred ordinary and
necessary business expenses for the taxable year 2002 for member
fees and real estate listing fees in the amounts of $300 and
$420, respectively. In reaching his determination of
petitioner’s 2002 income tax deficiency, respondent allowed a
personal exemption and a standard deduction in the amounts of
$3,000 and $3,925, respectively. During 2002, petitioner resided
with his wife and two children. There remains for our
2 Petitioner also had real estate rental income and
deductions, but this adjustment was not pursued and is considered
conceded by respondent.
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