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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
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