- 4 - On August 9, 1994, respondent mailed petitioner a statutory notice of deficiency determining an increase of $1,163 in petitioner's 1991 tax liability. On November 10, 1994, petitioner filed her petition with this Court, and on January 17, 1995, respondent filed her answer. From January through early June of 1995, respondent's Appeals Office and petitioner conducted settlement discussions. On June 11, 1995, petitioner mailed respondent's Appeals Office a letter with attached copies of billing records showing that petitioner had received $2,462 from Dr. Imhoff. The letter noted that the $2,462 amount was only $35 higher than the amount reported as miscellaneous income on the return. Petitioner proposed that respondent concede the $35 understatement. Also around this time, respondent obtained from Dr. Imhoff copies of checks paid to petitioner and ledgers maintained by Dr. Imhoff's office. After June 11 but prior to July 27, 1995, respondent concluded that: (1) The Form 1099-MISC prepared by Dr. Imhoff, which reported that petitioner had been paid $4,147.50, overstated amounts paid by $631.75; (2) the correct amount of wages from Dr. Imhoff was $3,515.75; (3) petitioner had understated income by $1,088.50 ($3,515.75-$2,427.25 of miscellaneous income reported on petitioner's return); (4) the $1,088.50 understatement resulted from petitioner's failure to report checks from Dr. Imhoff of $703.50, $350, and $35; and (5) petitioner qualified as an employee and would not be liable forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011