6
Wage Income
Gross income includes compensation for services. Sec. 61.
Petitioner admits that during 1993 Mrs. Schroeder received wages
in the amount of $170 from the DuPage County Board of Election
Commissioners. Petitioner does not contend that this amount is
excludable from gross income, and he has not established that
this amount was included in gross income reported on his joint
return for 1993. Respondent is sustained on this issue.
Self-Employment Tax
Petitioner contends that he provided services to Astron as
an employee, not as an independent contractor. Petitioner argues
that his compensation received from Astron is not subject to
self-employment tax. Respondent determined that petitioner is
liable for self-employment tax on his net earnings derived from
services performed for Astron because petitioner was acting as an
independent contractor.
A self-employment tax is imposed on net earnings of $400 or
more from self-employment income. Secs. 1401 and 1402(b). The
term "self-employment income" is defined as income derived by an
individual from carrying on a trade or business, less the
allowable deductions attributable to such trade or business.
Sec. 1402.
Whether an individual is an employee in a given situation is
a factual question to be determined by application of common-law
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