Patricia E. Ietto - Page 2

                                                    2                                                     
                  Respondent determined a deficiency in petitioner's Federal                              
            income tax for the taxable year 1991 in the amount of $172.                                   
            Respondent further determined that petitioner owed employment                                 
            taxes pursuant to the Federal Insurance Contributions Act (FICA                               
            taxes) in the amount of $1,209.  At the time of filing the                                    
            petition, petitioner resided in Fair Lawn, New Jersey.                                        
                  The issues are:  (1) Whether this Court has jurisdiction to                             
            review respondent's determination with respect to FICA taxes; and                             
            (2) whether petitioner underreported the amount of commission                                 
            income she received during 1991.                                                              
                                          FINDINGS OF FACT                                                
                  The facts may be summarized as follows.  During 1991,                                   
            petitioner was employed by the New York Partnership Exchange,                                 
            Inc. (NYPE).2  NYPE facilitated the sale of partnership                                       
            interests.  Petitioner received commissions for successfully                                  
            matching buyers and sellers.  On her 1991 Federal income tax                                  
            return petitioner reported commission income in the amount of                                 
            $14,684.  Petitioner prepared this return without the benefit of                              
            a Form 1099, which she received after April 15, 1992.  When the                               
            Form 1099 finally arrived, it indicated that petitioner received                              
            commission income in the amount of $15,813 for 1991.  Petitioner                              
            computed her 1991 commission income by adding the individual                                  


            2   Although initially the subject of some dispute, the                                       
            parties agree that petitioner served as an employee, and not as                               
            an independent contractor.                                                                    




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