Richard Clarke Randall - Page 2

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          petitioner’s 2003 taxable income includes nonemployee                       
          compensation not otherwise reported by him in that taxable                  
          income.  We hold that it does.  We also must decide whether                 
          petitioner is liable for the section 6662(a) accuracy-related               
          penalty.  We hold that he is.                                               
                                  FINDINGS OF FACT                                    
               Some facts are stipulated and are so found.  The stipulation           
          of facts and the accompanying exhibits are incorporated herein by           
          this reference.  Petitioner resided in Colorado when his petition           
          was filed.                                                                  
               In 2003, petitioner received $32,225 in nonemployee                    
          compensation from National Quality Assurance USA Inc., $20,517 in           
          nonemployee compensation from Labtest International Inc., $2,250            
          in nonemployee compensation from Inc., $44 in interest              
          income from Firstbank of Arapahoe County, and $242 in taxable               
          dividends from The Southern Company Services, Inc.  After                   
          receiving petitioner’s 2003 Form 1040EZ, Income Tax Return for              
          Single and Joint Filers With No Dependents, respondent issued to            
          petitioner a notice of proposed changes (CP-2000).  Thereafter,             
          petitioner filed a Form 1040X, Amended U.S. Individual Income Tax           
          Return, for 2003.  On this amended return, petitioner reported              
          that his adjusted gross income for 2003 was $501; this amount               
          consisted of $44 of interest income and $215 and $242 in                    
          dividends.  He reported total tax of zero.  Petitioner attached             

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