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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 Due.com 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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