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Respondent determined a deficiency of $126 in petitioners’
1997 Federal income tax. The issue for decision is whether
certain deductions claimed on a Schedule C, Profit or Loss from
Business, included with petitioners’ 1997 Federal income tax
return should be treated as unreimbursed employee business
expenses. The resolution of this issue depends upon whether
George A. Beitel was an independent contractor or an employee in
connection with services he provided as an adjunct professor at
certain universities in 1997.
Background
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. At the time the petition was
filed, they resided in Idaho Falls, Idaho. References to
petitioner are to George A. Beitel.
During 1997, in addition to his full time employment as an
engineer with the Idaho National Engineering and Environmental
Laboratory, petitioner, who holds a Ph.D. degree in physics, was
also an adjunct professor at Idaho State University (ISU) and at
the University of Idaho (UOI)(collectively, the universities).
Petitioner taught at the universities and was compensated
for so doing on a course-by-course basis. During the 1997 spring
semester, petitioner taught a class in Low Level Radioactive
Waste at ISU. During the 1997 fall semester, petitioner taught a
class in Systems Engineering Principles at UOI. Classes for
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