- 4 - * * * * * * * 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011