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Wrestling, Chicago Wrestling Club, Nevada Wrestling Club, Inc.,
and Phoenix Wrestling Club were affiliated with MBWC, and the
group will hereinafter be referred to as the Gagne organizations.
The Gagne organizations treated petitioner for income tax
purposes as an independent contractor and shortly after yearend
furnished him with Forms 1099 purporting to show the compensation
paid to him during the taxable year. For the year 1982, the
Forms 1099 furnished to petitioner showed that he received
$58,369 from MBWC, and amounts ranging from $5,450 down to $2,550
from three of the affiliated clubs. In 1983 the Forms 1099
issued to petitioner showed that he received $41,815 from MBWC,
$12,050 from the Chicago Wrestling Club, and amounts ranging from
a high of $5,550 to a low of $3,650 from the three other
affiliated wrestling clubs. For 1984 the Forms 1099 issued to
petitioner showed that he received $48,044.88 from MBWC, and
$11,660 from the Chicago Wrestling Club, and amounts ranging from
a high of $3,425 to a low of $2,550 from the other three
affiliated wrestling clubs.
During the years 1982, 1983, and 1984 petitioner also
wrestled for the Winnipeg Wrestling Club (also known as AM-CAN),
which was an additional member of the MBWC group. In 1983 AM-CAN
issued a statement of fees, commissions, or other amounts paid to
nonresidents of Canada to petitioner showing that AM-CAN had paid
gross income to petitioner of $11,650 in that year. During the
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