John Pryor Green - Page 3

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          payments for those years.  Petitioner was unmarried during the              
          subject years.                                                              
               Petitioner is a court reporter.  In 1987, he was engaged by            
          Patterson Reporting (Patterson), and Patterson paid him $18,165             
          for these engagements.  Patterson issued petitioner a Form                  
          1099-EC, Nonemployee Compensation, showing that it paid him this            
          amount.  During the 1988 through 1992 taxable years, petitioner             
          was engaged by Metro-Dade County (Metro), and Metro paid him for            
          these engagements.  Petitioner received Forms 1099-NEC from                 
          Metro, showing that Metro paid him $12,557 in 1988; $22,659 in              
          1989; $22,111 in 1990; $8,282 in 1991; and $6,508 in 1992.                  
          During the 1989 and 1990 taxable years, petitioner was engaged by           
          the State of Florida, and the State paid him for these                      
          engagements.  Petitioner received Forms 1099-NEC from the State             
          showing that it had paid him $858 in 1989 and $631 in 1990.                 
               During each of the subject years, petitioner was required to           
          (and did) furnish his own supplies.  He was required to furnish             
          most of his own equipment when he went out on assignment.  He did           
          his own transcribing and typing.                                            
               Respondent determined that petitioner did not file an income           
          tax return for any of the subject years, and she computed his tax           
          liability for those years.  First, respondent determined that               
          petitioner had received the income reported on the Forms                    
          1099-NEC.  Second, she referred to the Bureau of Labor Statistics           
          and determined that he had received additional amounts of taxable           




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