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During the years 1993, 1994, and 1995, petitioner worked as
a broadcast engineer for the radio station Family Life
Broadcasting System (FLBS) located in Tucson, Arizona. For the
year 1993, petitioner and FLBS entered into an agreement whereby
petitioner was classified as an independent contractor and was to
receive payments of $2,000 per month for part-time performance.
In 1993, petitioner received compensation of $24,000 from FLBS.
Petitioner submitted a 1993 Form 1040, U.S. Individual Income Tax
Return, which was received by the Internal Revenue Service on
August 24, 1994. Petitioner did not sign the return under
penalties of perjury, instead writing the words “under protest”
in the signature line. Petitioner attached to his Form 1040 the
following: (1) Schedule D, Capital Gains and Losses,; (2) Form
1099-MISC, showing $24,000 compensation from FLBS; (3) Statement
of Randal William Howard, which generally states that petitioner
is not liable for tax for 1993; and (4) Declaration of Randal
William Howard, which contained the following statement:
During the Year 1993, I sold labor each day that I
worked at the Family Life Broadcasting System. For the
Year 1993, I received $24,000.00 from the Family Life
Broadcasting System. Based upon the facts above, and
the provisions of the Internal Revenue Code (IRC),
�1015(a), I had a total basis (cost) of at least
$24,000.00 in the labor I sold to the Family Life
Broadcasting System.
Petitioner reported the $24,000 received from FLBS on Schedule D
as an amount received for “labor” and claimed a basis in the
labor of $24,000, resulting in zero gain. No tax was withheld
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