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Year Deficiency 6651(a)(1) 6654
1991 $11,214 $2,804 $645
1993 1,156 289 ---
We must decide the following issues:
1. Whether petitioner's 1991 gross income includes the
$38,390 amount reported to him on a 1991 Form 1099, Wage and Tax
Statement. We hold it includes only 50 percent of this amount.
2. Whether petitioner's 1993 gross income includes the
$7,365 amount reported to him on a 1993 Form 1099. We hold it
does not.
3. Whether petitioner is liable for the additions to tax
determined by respondent. We hold he is to the extent described
herein.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure. Dollar amounts are
rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Escondido, California, when he petitioned the Court.
During 1991, petitioner worked as an independent contractor
washing the windows of model homes in the vicinity of San Diego,
California. Petitioner received assignments on a monthly basis
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Last modified: May 25, 2011