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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