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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.
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Last modified: May 25, 2011