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$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.
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