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negotiated the terms of the engagement based upon the unions’ fee
schedule. Compensation for all other assignments was negotiated
outside of the unions’ fee schedule. It is unclear from the
record whether fees were negotiated based on an hourly rate or on
a fixed amount per engagement. Nevertheless, petitioner received
a separate paycheck stub for each job completed and in most cases
a Form W-2, Wage and Tax Statement, for services rendered.1
In addition to work assignments procured by his agents,
petitioner solicited additional work by mailing promotional
compact disks containing samples of his commercials and
announcements directly to producers of various entertainment
companies. With regard to all types of engagements, petitioner
made the final determination whether to accept or to reject the
work. Most of petitioner’s assignments were completed at studio
facilities arranged by the company at a time mutually convenient
for both parties. Any tools or other materials necessary for the
assignment were provided by both petitioner and the hiring
company. Petitioner testified that he did not work “full time”
for a particular company during the year in issue.
Petitioner reported Schedule C gross income in the amount of
$189,173 on his 1994 Federal income tax return. It comprises
1 For 1994, 94.93 percent of petitioner’s Schedule C income
was reported on Forms W-2 and the remaining 5.07 percent of
petitioner’s Schedule C income was reported on Forms 1099.
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Last modified: May 25, 2011