106 T.C. No. 14 UNITED STATES TAX COURT JOHN D. AND KAREN BEATTY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Docket No. 8273-94. Filed April 17, 1996. P, an Indiana county sheriff, was required by State statute to provide meals to the prisoners incarcerated in the county jail. The costs of providing the meals were borne by P. P received a meal allowance from the county on a per meal basis at a specified rate established by the State. P claims that he provided the meals to the county prisoners as an independent contractor, and reported the meal allowances received and costs incurred on a Schedule C. R contends that P provided the meals to the county prisoners as an employee of the county and must deduct such costs on a Schedule A as employee business expenses. Held: The costs of the meals constitute costs of goods sold and are taken into account in the determination of P's gross income. Consequently, under the circumstances of this case, it makes no difference for Federal income tax purposes, whether P provided the meals to the prisoners as an independent contractor or county employee. Stephen E. Arthur and Ronald M. Soskin, for petitioners. Ronald T. Jordan, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 Next
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