- 22 - As such, I am a “Nonresident Alien” {as such ‘word of art’ is defined in IRC Sec. 7701(b)(1)(B)} under United States Tax Laws [Title 26 United States Code and the Internal Revenue Code][.] 26 CFR Sec 31.3401(a)(6)-1(b) “Remuneration paid to a nonresident alien individual...is exempted from wages and hence is not subject to withholding.” Petitioners issued to Susan Thomas Barmes and to Jennifer Burgess16 Form W-2, Wage and Tax Statement (Form W-2), for the respective wages that they earned for the period January 1, 1995, through October 12, 1995. As of October 23, 2000, the date of the trial in this case, petitioners, Sandbar Wholesale Trust, and Sandbar Real Estate Trust had not issued to the business employ- ees Forms W-2 or Forms 1099-MISC, Miscellaneous Income (or any other type of Form 1099), for any periods after 1995. Petitioners’ Real Properties At all relevant times until at least October 12, 1995, petitioners owned the two parcels of real property on which the business locations were situated. At those times, petitioners also owned approximately 17.73 acres of land located at 6393 E. Overhead Road, Fritchton, Indiana (the Fritchton property), which was approximately 6.5 miles from the business locations. Peti- tioners’ personal residence and an old farmhouse (old farmhouse) were situated on the Fritchton property. In 1994, petitioners remodeled the old farmhouse and furnished it as an office. 16During the year at issue, Susan Thomas Barmes and Jennifer Burgess were petitioners’ daughters-in-law.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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