Randal W. Howard - Page 3




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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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