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* * * * * * *
12. Second, the requirement to make a return at 26
U.S.C. � 6012 is “triggered” only when the Petitioner’s
income exceeds the “exempt amount.”
13. 26 U.S.C. � 6012(a)(1)(D)(ii) assigns the “exempt
amount” the same meaning as � 151(d).
* * * * * * *
SECOND ERROR
* * * * * * *
39. Petitioner disputes the allegation he owes
$9,619.40 as an increase in tax for tax year 2003.
* * * * * * *
CLAIM OF PETITIONER
42. First, Respondent alleges Petitioner received
“compensation” or “remuneration” classified as a
“taxable distribution” in the amount of $42,154.00 in
2003.
43. Petitioner disputes the amount as to accuracy.
44. Petitioner disputes the amount of the “taxable
distribution” as “gain” or “income,” as it represents
total proceeds from the disbursement of brokerage items
and not a “net” amount.
* * * * * * *
50. Second, Respondent alleges Petitioner received
“compensation” or “remuneration” classified as “stock
sales” in the amount of $24.00 in 2003.
51. Petitioner disputes the amount of “stock sales” as
“gain” or “income,” as it represents total proceeds
from the sale of brokerage items and not the “net”
amount.
* * * * * * *
THIRD ERROR
* * * * * * *
60. Petitioner disputes the allegation he owes $529.07
as an IRC 6651(a)(2) penalty for 2003.
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