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that he was unable to recall whether he resold the aforementioned
merchandise or gave it away; but he acknowledged that he might
have resold the merchandise to others. Respondent contends that
the types of transactions for which Masterguard might issue a
Form 1099 to an individual who purchases its merchandise include:
(1) Override payments made to an independent authorized dealer on
purchases made by other independent authorized dealers; and (2)
refunds for products purchased directly by the independent
authorized dealer. During cross-examination, petitioner
acknowledged that according to Masterguard, the company makes
override payments and also issues rebates to individuals who
purchase merchandise from Masterguard.
Petitioner claims that he is unable to recall from what
sources he received income in 1988 due to subsequent problems he
had with his health. Petitioner's only recollection of how he
earned a living in 1988 is that he's "been self-supporting since
I was about 14." Petitioner also claims to have no records
relating to any income he received in 1988. During cross-
examination petitioner asserted his Fifth Amendment rights and
refused to answer questions posed to him by respondent's counsel
concerning petitioner's marital status or whether petitioner has
any children.
Respondent determined that because of petitioner's receipt
of nonemployee compensation in the amount of $20,309 from
Masterguard in 1988, petitioner is subject to self-employment tax
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