- 5 - month from her brother in 1996 for this purpose. Petitioners timely filed a Federal income tax return, Form 1040, for 1996. Petitioners attached to their return Schedule C, Profit or Loss From Business, relating to Mr. Sasser’s business. On his Schedule C, Mr. Sasser reported gross receipts in the total amount of $5,635. This amount corresponds with the amount of nonemployee compensation reported on a Form 1099-MISC that Evans City issued to Mr. Sasser. Insofar as his arrangement with Mr. Roach was concerned, Mr. Sasser did not claim any reduction in gross receipts for cost of labor, nor did he claim any deduction for subcontract labor. In the notice of deficiency, respondent determined that petitioners failed to report $8,352 of nonemployee compensation. Respondent’s determination is based on a Form 1099-MISC filed by Mr. Roach claiming that he paid $8,352 to Mr. Sasser in 1996. Respondent sought to confirm this specific item adjustment by a bank deposits analysis that demonstrated, in respondent’s view, that Mr. Sasser had between $6,730 and $11,829 of unreported income in 1996. Discussion At trial, respondent called Mr. Roach as a witness and introduced Mr. Roach’s “daily planner” as an exhibit. In respondent’s view, Mr. Roach’s testimony and records corroborate the Form 1099-MISC showing the payment of $8,352 of nonemployeePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011