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Statement (Form W-2); Data Search paid Mr. Larson $2,500 in
nonemployee compensation that it reported in Form 1099-MISC,
Miscellaneous Income (Form 1099); and Windermere paid Mr. Larson
$63,233 in wages that it reported in Form W-2 and $21,891.95 in
nonemployee compensation that it reported in Form 1099.3
Due to a printing alignment error in Form 1099 that
Windermere issued to Mr. Larson for 1999 in which it reported
that it paid Mr. Larson $21,891.95 in nonemployee compensation,
the first digit of that amount of nonemployee compensation (i.e.,
“2”) appeared in that form on top of the preprinted dollar sign
(i.e., “$”) that appeared in that form. (We shall refer to the
foregoing printing alignment error as the alignment error).
Because of the alignment error, it was not readily apparent from
reviewing Form 1099 that Windermere issued to Mr. Larson for 1999
that the amount of nonemployee compensation reported therein was
$21,891.95, as opposed to $1,891.95.
From January 2002 until about three weeks before the time of
the trial in this case, Mr. Larson was the president and the
chief financial officer of Mooney Aerospace. About three weeks
before the trial in this case, Mr. Larson became the chief
executive officer of that company.
Sometime on or after April 16, 2000, petitioners jointly
3During 1999, Windermere also made $2 in medical payments to
Mr. Larson.
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Last modified: May 25, 2011