- 2 - $1,579.25 and section 6654(a) in the amount of $325.47. The issues for decision are: (1) Whether petitioner received and failed to report taxable income in the amount of $25,836; (2) whether petitioner is liable for self-employment tax in the amount of $3,651; (3) whether petitioner is liable for the delinquency addition to tax under section 6651(a)(1); and (4) whether petitioner is liable for the addition to tax for failure to pay estimated tax under section 6654(a). Some of the facts have been stipulated, and the stipulation of facts is incorporated herein by reference. Petitioner resided in California at the time his petition was filed. Prior to 1994, petitioner had been a carpenter working for various movie studios. Petitioner stopped working for a time because he was “burned out”. In 1994, petitioner was hired by Clairmont Camera Inc. (Clairmont) to develop a “quiet camera” room. Clairmont submitted to the Internal Revenue Service a Form 1099-MISC for 1994 reflecting that it had paid petitioner $25,836.92 for 1994. The record reflects checks issued from Clairmont to petitioner totaling that amount in 1994. However, two of those checks, totaling $3,381.92, were issued by Clairmont for the reimbursement of materials used in the development of the quiet camera room. In the notice of deficiency issued to petitioner on April 18, 1997, respondent determined that petitioner received income of $25,836. Respondent now concedes that petitioner’s income for 1994 from Clairmont was only $22,455.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011