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proposed changes, petitioner should submit a signed letter of
explanation and supporting documentation.
On February 15, 1994, petitioner informed respondent that
she disagreed with respondent's proposed changes. On
February 18, 1994, petitioner mailed respondent a letter further
delineating her position. In the letter, petitioner conceded
that her return should have included the interest income but
disputed that her return omitted $4,147.50 of other income.
Petitioner asserted that for the 1991 tax year she: (1) Did not
receive a Form 1099-MISC from Dr. Imhoff; (2) estimated her
income from Dr. Imhoff and reported it as $2,427.25 of
miscellaneous income on her return; (3) was an employee (not an
independent contractor) of Dr. Imhoff and thus received employee
wages rather than self-employment income; and (4) did not owe any
additional Federal Insurance Contributions Act (FICA) tax.
On April 4, 1994, respondent replied to petitioner's letter
but did not address petitioner's contentions as set forth in the
February 18, 1994, letter. On April 26, 1994, petitioner again
wrote to respondent and requested that respondent address the
positions taken by petitioner in her letter. On May 18, 1994,
respondent requested information from Dr. Imhoff. Dr. Imhoff
responded on June 16, 1994, by asserting, as he did on the Form
1099-MISC filed with the Internal Revenue Service (IRS), that the
$4,147.50 constituted nonemployee income.
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