Daniel J. and Joyce A. Roderick - Page 4

                                        - 3 -                                         
          reference and are found as facts.  At the time of filing the                
          petition, petitioners resided in Alpharetta, Georgia.  Petitioner           
          entered into a short-term consulting agreement with his former              
          employer, GMAC, after his position was eliminated.  Petitioner              
          submitted invoices to GMAC on February 1 and March 1, 2003,                 
          totaling $43,977.76 and $34,967.70, respectively, for services              
          rendered and expenses incurred.  Both invoices instructed GMAC to           
          wire transfer payment to a Bank of America account “For Benefit             
          of Daniel J. Roderick” and listed petitioner’s Bank of America              
          account number and Social Security number.  GMAC paid                       
          petitioner’s invoices on February 12 and March 26, 2003.  Despite           
          receiving payment for the consulting services that petitioner               
          performed for GMAC, petitioners failed to include those amounts             
          on their 2003 tax return.  Petitioners also failed to include on            
          their 2003 tax return $7,552 in pension and annuity distribution            
          income that petitioner received from Fidelity Investments.                  
                                     Discussion                                       
               Petitioner concedes that he received compensation from GMAC            
          and pension and annuity income from Fidelity Investments and that           
          he should have reported both receipts on petitioners’ 2003 tax              
          return.  Petitioner contends, however, that he transferred                  
          $39,249.70 to Kathleen A. Mulvey (Ms. Mulvey), who performed some           









Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011