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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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Last modified: May 25, 2011