Michael S. Palmer - Page 3

                                          3                                           
               During 1992 and 1993, petitioner did construction work as a            
          subcontractor for Mark A. Palmer, Inc. (MAP).  MAP paid                     
          petitioner $119,492 in 1992 and $106,695 in 1993.  MAP issued               
          Forms 1099-Misc to petitioner showing that it had paid him                  
          nonemployee compensation in these amounts.  MAP withheld no                 
          Federal income tax from its payments to petitioner for 1992 or              
          1993.                                                                       
               Petitioner did not file individual income tax returns for              
          1992 and 1993.                                                              
          B.   Notice of Deficiency                                                   
               On April 25, 1995, respondent mailed petitioner a notice of            
          deficiency.  In it, respondent determined that MAP's payments to            
          petitioner were income to him and that petitioner had business              
          expenses of $17,924 for 1992 and $16,004 for 1993 (15 percent of            
          his compensation).                                                          
               Petitioner did not issue Forms W-2 (wage statements) or                
          Forms 1099 (income statements) to any subcontractors.  Petitioner           
          offered into evidence no canceled checks or receipts showing that           
          he paid subcontractors.                                                     
                                       OPINION                                        
          A. Petitioner's Tax Protester Contentions                                   
               Petitioner makes several tax protester arguments and                   
          submitted related documents and other materials which purportedly           
          support his contention that he is not subject to Federal income             






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