- 4 - income in 1988, 1991, and 1992. Third, she determined that he was liable for self-employment tax on all of his unreported income. Fourth, she determined that he could deduct the standard deduction for each year, and that he could deduct one-half of his self-employment tax for 1990, 1991, and 1992. Fifth, she determined that his filing status was “Single”, and that he was entitled to one exemption. Sixth, she determined that he was liable for the additions to tax mentioned above. OPINION 1. Taxable Income Respondent determined that the amounts listed on the Forms 1099-NEC were includable in petitioner’s gross income. She also referred to the Bureau of Labor Statistics, and determined that petitioner received additional taxable income in 1988, 1991, and 1992. In his opening argument at trial, respondent’s counsel conceded the adjustments based on the labor statistics. At the outset, we note that we need not, and do not, reach the issue involved in Portillo v. Commissioner, 932 F.2d 1128 (5th Cir. 1991), affg. in part and revg. in part T.C. Memo. 1990-68, because petitioner has not challenged the accuracy of the Forms 1099-NEC issued to him. As we understand petitioner’s argument, he performed his court reporting assignments as an employee of Patterson, Metro, and the State of Florida, and he was not an independent contractor as determined by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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