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After graduating from law school, petitioner moved to New
York City so that he would be able to take a bar preparation
course for the California bar exam. In September 2003,
petitioner moved from New York City to Palo Alto, California, to
work as a securities associate with the law firm of Simpson
Thacher & Bartlett (STB). Before starting at STB, petitioner
received an advance from STB to cover the costs associated with
his move from New York City to Palo Alto.
Petitioner timely filed his 2003 Federal income tax return.
Petitioner reported wages, salaries, and tips on his return. His
wages of $51,304 were earned from his employment at STB from
September through December of 2003.
Respondent received the following third party information for
petitioner that was not otherwise reflected on his 2003 income
tax return: (1) Interest income on Wachovia Bank accounts of $7
and $9, (2) a pension and annuity payment of $16,263 (with income
tax withheld of $3,252), and (3) student loan interest payments
of $1,509 paid to Student Financial Assistance and $1,516 paid to
Duke University.
Respondent issued to petitioner a notice of deficiency that
explained the changes made to his 2003 Federal income tax based
on the third-party information. The notice showed that
petitioner had understated his income tax on his 2003 return by
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