Raymond Verni Schroeder - Page 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            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011