-2-
6651(a)(1) in the respective amounts of $5,137 and $664.
Petitioner resided in Huntsville, Alabama, at the time the
petition was filed.
The issue is whether this Court has jurisdiction to
adjudicate petitioner's dispute with Westinghouse Electric Corp.
(Westinghouse) and/or Commonwealth Edison Co. (Edison).
The facts are undisputed and may be summarized as follows.
Edison operated a nuclear power plant in Zion, Illinois, during
1990. Edison contracted with Westinghouse to supply certain
training services at Zion, and Westinghouse contracted with
petitioner to supply those services. Westinghouse's contract
with petitioner provided that petitioner would be paid $31 per
hour. Under the contract between Westinghouse and Edison,
Westinghouse apparently was paid $45 per hour. Westinghouse
terminated the contract it had with petitioner in June of 1990.
Westinghouse paid petitioner $17,918 during 1990. In 1990,
petitioner also received $2,515 in unemployment compensation,
$12,218 as wages from various employers, and $14 of interest
income.
For reasons discussed infra, petitioner did not file a
Federal income tax return for 1990. The income set forth above
constitutes the predicate for the notice of deficiency.
Petitioner does not dispute that he received the income, nor does
he contest the computation of the tax. Rather, as we understand,
petitioner contends that he was an employee of Edison and that he
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