Don H. Wisden - Page 11

                                       - 11 -                                         
          Petitioner was no more specific about the income he earned in               
          1990 than he was with respect to 1989.                                      
               In the notice of deficiency, in addition to an adjustment              
          based upon BLS statistics, respondent determined that petitioner            
          earned $6,792 in nonemployee compensation and had wage income in            
          the amount of $5,729.  The sources of the nonemployee                       
          compensation and wage income were not specifically identified,              
          but petitioner did not specifically deny the receipt of such                
          income.  We assume that the sources of income were Tucson                   
          Newspapers, Inc., and Delivery Services, Inc.  Having found                 
          petitioner to be a credible witness, we accept his contention               
          that he had no other sources of income for the year 1990.  We               
          further find that the nonemployee compensation is subject to the            
          self-employment tax imposed by section 1401.  We reject the                 
          portion of respondent's adjustment that is based upon BLS                   
          statistics.                                                                 
               1991                                                                   
               Although the exact date is unknown, petitioner moved to St.            
          George, Utah, in late 1990.  After he moved to St. George,                  
          petitioner worked for Everex, Heritage, and Peppermill.  Based              
          upon his testimony we find that he earned the following income in           
          connection with these jobs:                                                 
               Employer  Amount    Computation                                        
               Everex    $2,280    12 weeks x 40 hrs. per week x $4.75 per hr.        
               Heritage  2,160     12 weeks x 40 hrs. per week x  4.50 per hr.        
               Peppermill  2,640   12 weeks x 40 hrs. per week x  5.50 per hr.        





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011