- 3 -
in the amounts of $52,456, $60,970, $74,925, and $79,360, re-
spectively.
On January 24, 1995, petitioner and Biddle executed what
purported to be a contract which was entitled "CONTRACT BETWEEN
TRADESMAN/LABORER/CRAFTSMAN AND PROPERTY OWNER". That document
stated in pertinent part:
In the absence of "real" money (commodity money), the
TRADESMAN [petitioner] offers to trade his property at
the rate of _________ Federal Reserve Notes (FRN's) for
each hour of labor expended on behalf of the PROPERTY
OWNER [Biddle]. The TRADESMAN does not receive the
FRN's as equal trade value for his property, but for
the potential opportunity to trade said FRN's for
something of actual value. However, the PROPERTY OWNER
is immediately, upon receipt of the FRN's by the
TRADESMAN, relieved of any further obligations to the
TRADESMAN for the labor for which said FRN's were
given.
* * * * * * *
TRADESMAN is specifically NOT the employee of the
PROPERTY OWNER, nor is he an "independent contractor".
During 1992 and 1993, petitioner received taxable interest
income from Great Western Bank in the amounts of $149 and $88,
respectively. During 1992, he also received self-employment
income from NTS Sabal Golf Villas in the amount of $181.
Biddle and the other payors of income to petitioner during
the years at issue reported the payment of such income to the
Internal Revenue Service (Service).
Petitioner made estimated tax payments for 1992 in the
amounts of $1,800, $2,000, and $2,500 on April 20, 1992, June 20,
1992, and September 23, 1992, respectively. Petitioner made no
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011