Ertan and Susan Eren - Page 7

                                                   -7-                                                     
            December 4, 1987, and December 20, 1988), provides that overseas                               
            PSC's treat a contractor as an FBO government employee for all                                 
            purposes except retirement.                                                                    
                  Petitioner was notified by a December 12, 1989, FBO memorandum                           
            that as a result of an Internal Revenue Service review of FBO                                  
            personnel policies, it was determined that PSC's signed by FBO                                 
            contractors created an employee-employer relationship between the                              
            parties and that petitioner should designate himself as an FBO                                 
            employee (rather than as an independent contractor) on his 1989                                
            Federal income tax return.                                                                     
                  Subsequent to the issuance of this memorandum, FBO issued                                
            petitioner a Form W-2 for "wages, tips and other compensation" in                              
            the amount of $74,183.04.  FBO withheld Social Security tax from                               
            petitioner's income in the amount of $3,604.80.                                                
            Petitioners' 1989 Federal Income Tax Return                                                    
                  On petitioners' 1989 Form 1040, petitioners reported $74,183                             
            as "business income" on line 12 and then subtracted $70,0005 on                                
            line 22 ("other income") with the notation "Exclusion from Form                                
            2555."6  Thus, petitioner claimed a section 911 exclusion for a                                



            5            The maximum amount permitted for the earned income                                
            exclusion was $70,000.                                                                         
            6            Form 2555, Foreign Earned Income, attached to                                     
            petitioners' 1989 return, reported foreign earned income of                                    
            $74,183, and listed "name of employer" as "self".                                              





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