Lawrence W. Wirenius - Page 2




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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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