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 incomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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