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Respondent determined deficiencies of $5,974 and $6,459, in
petitioners’ Federal income taxes for the years 1993 and 1994,
respectively. For each year, the issues for decision are: (1)
Whether petitioners are entitled to trade or business expense
deductions in excess of the amounts allowed by respondent, and
(2) whether Jack C. Goins, Sr. performed services as an insurance
examiner for the Commonwealth of Kentucky as an independent
contractor or employee.
Background
Some of the facts have been stipulated and are so found.
Petitioners filed a timely joint Federal income tax return for
each year in issue. At the time the petition was filed, they
resided in Frankfort, Kentucky. References to petitioner are to
Jack C. Goins, Sr.
Petitioner began performing services for the Commonwealth of
Kentucky Department of Insurance (DOI) as a market conduct
examiner on April 1, 1969. Over the years his position was
classified at times as an independent contractor and at times as
an employee. His working arrangement with DOI ended on June 30,
1996.
On July 3, 1996, petitioner filed a claim for unemployment
insurance benefits, claiming that he was laid off by his employer
on June 30, 1996. After an administrative hearing before a
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