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deductions for the taxable year 1994. We find that petitioner is
an employee and not an independent contractor and therefore
cannot deduct his business expenses on Schedule C.
FINDINGS OF FACT
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, petitioner resided in Chicago, Illinois.
In 1994, petitioner, under the stage name Tony Russell,
worked as a voice actor providing voice announcements and/or
narration for commercials, corporate videos, radio and television
promotionals, video games, talking toys, and television shows.
Although petitioner provided services for television, cable, and
video, petitioner did not appear on screen. Petitioner began his
career as a voice actor by studying communications at the
University of Wisconsin. Between the years 1977 and 1983,
petitioner worked with NBC as both booth announcer on television
and a “swing personality” on radio stations. After working with
NBC, petitioner began providing services to various parties on a
contractual basis.
During the year in issue, petitioner was a member of both
the Screen Actors Guild and the American Federation of Television
and Radio Artists (unions). The unions set minimum standards for
performer fees based on a collective bargaining agreement and
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