- 2 - The issues for decision are:2 (1) Whether petitioners received nonemployee compensation in the amount of $14,288; (2) whether petitioners are entitled to deduct Schedule C expenses in the amount of $6,811; and (3) whether petitioners are liable for the accuracy-related penalty under section 6662(a). Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioners resided in Pasadena, California. Background Sony Jean Baptiste (petitioner) earned his living as a truck driver in 1994. From January 1, 1994 to May 2, 1994, petitioner worked for Ortega Trucking (Ortega), the owner of which is Charles Ortega (Mr. Ortega). Petitioner would drive one of Ortega’s trucks to Pacific Railroad where he would pick up a shipment. Petitioner would then transport this shipment to various warehouses for unloading. Some of the warehouses to which petitioner delivered had their own employees help unload the trucks. Other warehouses did not, and petitioner would hire “lumpers” to help unload. The lumpers would wait in the vicinity of the warehouse for the trucks to come in. According to petitioner, he would negotiate a price with the lumpers and would pay them about $60 or $65 and sometimes $80. If petitioner needed help unloading a double 2 Petitioners conceded that they received a tax refund of $2,535 for the 1994 taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011