- 3 - in and around Reno, Nevada, for his process services. Petitioner considered himself an independent contractor for tax purposes. He reported his process-serving income and claimed his expenses on his Federal income tax returns on a Schedule C, Profit or Loss From Business. Petitioner realized a net profit for each of the years at issue. Petitioner's earnings from his activity were paid to him by the Messenger Service. For each year at issue, the Messenger Service issued to petitioner Internal Revenue Service (IRS) Forms W-2, Wage and Tax Statement, reflecting the amounts paid to petitioner for his services. The Forms W-2 classified petitioner's remunerations as wages. The Messenger Service withheld Social Security and Federal income taxes on the payments. Petitioner, however, on his Federal income tax returns, reported the Form W-2 amounts as gross income on Schedule C. Petitioner claimed deductions for expenses related to his activity, consisting of car and truck expenses, meals and entertainment, and utilities. Although he realized a net profit for each of the years at issue, petitioner did not include with his returns the appropriate schedules for self-employment taxes. In the notice of deficiency, respondent determined that petitioner was not an independent contractor but, rather, was an employee and that his earnings from the Messenger Service constituted salary or wages. Respondent further determined thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011