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same period the salaries and wages paid to employees for each
year was zero dollars, with the exception of 1987 in which
petitioner reported $801.01 as salaries and wages. Thus,
petitioner reported that it did not pay either Robert or Charlene
Peers any compensation for their services as officers of
petitioner, and that petitioner paid only $801.01 as salaries and
wages for the years at issue.
Rather than treating the remuneration of Robert and Charlene
Peers as compensation paid to officers or as salaries and wages
paid to employees, petitioner treated payments to the Peerses as
commissions paid to independent contractors. Petitioner's
corporate income tax returns, Forms 1120, for the years at issue,
indicate that the commissions paid to nonemployees who were
treated by petitioner as independent contractors for each year
were as follows:
Year Commissions
1987 $45,000
1988 68,000
1989 67,000
1990 65,800
We note that petitioner alleged no facts in its petition, its
amended petition, or its second amended petition to challenge the
treatment of the amounts as payments to independent contractors,
which treatment was clearly described in respondent's final
revocation letter.
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