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petitioner was liable for self-employment tax in respect of the
nonemployee compensation reported to respondent on the previously
mentioned Forms 1099-NEC.
Petitioner filed an imperfect petition, followed by an
amended petition, in which he contested liability for self-
employment tax, as well as the amount of the compensation
reportedly paid to him for the taxable years 1991 and 1992. At
the time that the petition was filed, petitioner resided in
Thorndike, Massachusetts.
By notice dated June 11, 1996, petitioner's case was set for
trial on September 3, 1996, in Boston, Massachusetts. On August
6, 1996, Appeals Officer Richard Puzzo forwarded to petitioner a
proposed form of decision and an audit report. The form of
decision included a reduction in the amount of the deficiencies
and additions to tax determined in the notice of deficiency, as
follows:
Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1991 $4,413 $1,103
1992 1,748 437
The accompanying audit statement clearly revealed: (1) Respondent
computed the reduced deficiencies based on petitioner's receipt
of nonemployee compensation (albeit in lower amounts relative to
the amounts determined in the notice of deficiency); and (2) such
compensation was subject to self-employment tax.
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