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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