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must therefore include in his gross income $6,292 and $6,360 for
2000 and 2001, respectively.6
Petitioner timely filed a petition with the Court disputing
respondent’s deficiency determinations. In the petition,
petitioner contends that he “does not feel the 1099 income
represents taxable income since the housing was for the
convenience of his employer and the U.S. govt.”
Petitioner listed his mailing address as being in
Washington, Missouri, at the time he filed his petition.
Petitioner’s Amended Returns
At about the same time that petitioner filed his petition
for redetermination with the Court, he submitted to respondent a
Form 1040X, Amended U.S. Individual Income Tax Return, for each
of the 2 taxable years in issue.
The Form 1040X for 2000 incorporates a Schedule C, Profit or
Loss From Business. The Schedule C does not identify any
business or profession or any product or service, nor does it
list a business name or address. Rather, it simply reports gross
income of $6,292; i.e., the value of the lodging furnished to
petitioner in 2000 as reported on the Form 1099-MISC issued by
6 The $20 discrepancy between the amount reported by the
Air Force on the Form 1099-MISC, Miscellaneous Income, for 2001
($6,380) and the adjustment in the notice of deficiency for that
year ($6,360) appears to be attributable to a typographical
error. In view of the fact that the discrepancy is both de
minimis and in petitioner’s favor, we shall ignore it in ruling
on respondent’s motion.
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