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rather, he has consulted fellow missionaries when he has had
questions about missionary activities.
4. Petitioners' Tax Return and the Notice of Deficiency
The National Church issued petitioner Form 1099-MISC. Such
Form reflected nonemployee compensation for services rendered and
indicated that Federal income tax was not withheld from that
compensation. Petitioner reported his missionary-related income
and expenses on Schedule C.
Respondent does not challenge the amount of petitioners'
claimed business expenses. Rather, in her notice of deficiency,
respondent determined that petitioner was an employee rather than
an independent contractor in 1992. As a result of this
determination, respondent reclassified the expenses claimed by
petitioner on his Schedule C as Schedule A expenses deductible
only as miscellaneous itemized deductions, subject to the 2-
percent limitation under section 67.
ULTIMATE FINDING OF FACT
Petitioner, an endorsed Assemblies of God missionary, was an
independent contractor in 1992.
OPINION
Petitioners contend that petitioner was an independent
contractor and, as such, was entitled to deduct the full amount
of his business expenses on Schedule C pursuant to section 162.
Respondent determined that petitioner was an employee during
1992. Petitioners bear the burden of proving that respondent's
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