John D. and Karen Beatty - Page 10

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          difference in this case whether petitioner reports the income               
          from the program as an independent contractor or as an employee             
          of Howard County.  Consequently, we decline to address the                  
          question whether petitioner acted as an employee or independent             
          contractor of Howard County with respect to the program.  Under             
          the circumstances of this case, such a distinction gives rise to            
          no Federal income tax consequences.                                         
               As we view the case, the determination of petitioner's 1991            
          gross income from the program is all that is necessary to resolve           
          the controversy between the parties, and that income is easily              
          determined.  It is $41,412, computed by subtracting cost of goods           
          sold from the gross receipts petitioner received with respect to            
          the program.  That was the amount petitioner was required to                
          report, and did report, on his 1991 Federal income tax return.              
          To reflect the foregoing and the settled issues,                            


                                             Decision will be entered                 
                                        under Rule 155.                               


















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