- 9 - respondent attributed to him in the notice of deficiency. Initially, petitioner took the position that he was not a "taxpayer" for the years in issue, and attempted at trial to present support for that proposition; however, it appears that petitioner has abandoned that position3 and essentially only disputes respondent's determinations based upon the use of the BLS statistics and her determinations that certain of his income was subject to the self-employment tax. As we view the case, we need only determine the amount and characterization of the compensation that petitioner received during each year. Our analysis, which follows on a year-by-year basis, takes into account the presumption of correctness applicable to respondent's determinations, and our impression that petitioner was a credible witness at trial. 1989 During 1989, petitioner worked as a newspaper carrier for Tucson Newspapers, Inc., and as a delivery person for Delivery Services, Inc. Petitioner could not remember, and did not estimate at trial, how much he earned from either of these jobs, 3In a chambers conference that took place following the trial, the Court warned petitioner against presenting frivolous arguments in his brief and called his attention to sec. 6673. Petitioner complained in his brief that he was "intimidated" by the Court during this conference. Due either to this perceived intimidation, or the exercise of sound judgment, to his credit, for the most part, he heeded the warning.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011