- 2 - Background Larry C. Gamsby (petitioner) failed to file income tax returns for the taxable years 1991 and 1992. However, respondent received Forms 1099-NEC from 2 payors indicating that petitioner received nonemployee compensation in the amount of $24,910 and $26,673 for the taxable years 1991 and 1992, respectively. Revenue Agent Joan Rice conducted an examination of petitioner's tax liability for 1991 and 1992. By letter dated November 22, 1994, Revenue Agent Rice forwarded a copy of her revenue agent's report to petitioner and advised petitioner that, despite the Forms 1099-NEC filed with respondent, the facts supported petitioner's contention that petitioner should be classified as an employee for the taxable years in issue. On September 13, 1995, respondent issued a notice of deficiency to petitioner. In the notice, respondent determined that petitioner was liable for deficiencies in and additions to his Federal income taxes for 1991 and 1992 as follows: Addition to Tax Year Deficiency Sec. 6651(a)(1)1 1991 $6,164 $1,541 1992 6,600 1,650 Contrary to the conclusion reached by Revenue Agent Rice in her report, respondent determined in the notice of deficiency that 1 All section references are to the Internal Revenue Code, as amended; all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011