Helena Culver Fraser - Page 3

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          worked as a physician's assistant for multiple employers and                
          received wages in the amounts of $50,882 and $67,131,                       
          respectively.  During 1991, 1992, and 1993, petitioner earned               
          nonemployee compensation from her self-employment as a                      
          physician's assistant in the amounts of $3,500, $2,115, and                 
          $71,291, respectively.  In addition, petitioner received                    
          unemployment compensation in the amount of $920 in 1992 and                 
          interest income in the amount of $12 in 1991.  In total,                    
          petitioner received income during the years in issue as follows:            
                         Year                     Amount                              
                         1991                     $54,382                             
                         1992                     69,246                              
                         1993                     71,291                              
               Petitioner did not file income tax returns for any of the              
          years in issue, nor was any tax withheld or paid on income that             
          she earned in those years.                                                  
               Petitioner argues that her income was from her employment              
          and falls under the provisions of subtitle C.  This Court lacks             
          jurisdiction in matters arising under subtitle C.  Sec. 7442;               
          Judd v. Commissioner, 74 T.C. 651, 652-653 (1980).  Accordingly,            
          petitioner contends that we lack subject matter jurisdiction over           
          this case.  Subtitle C imposes employment tax on wages of                   
          individuals required to be withheld by employers which is in                
          addition to income tax imposed by subtitle A.  Subtitle A imposes           
          an income tax on an individual's taxable income, determined from            
          gross income.  Section 61(a) defines gross income as "income from           

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