- 4 - 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008