- 2 - Respondent determined a deficiency in petitioner’s 1997 Federal income tax in the amount of $7,562, and an accuracy- related penalty under section 6662(a)(1) in the amount of $1,512. After concessions by petitioner,1 the issues for decision are: (1) Whether petitioner failed to report $24,000 on his 1997 Federal income tax return; (2) whether petitioner is subject to the self-employment tax on this amount; and (3) whether petitioner is liable for an accuracy-related penalty under section 6662(a). Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of filing the petition, petitioner resided in Oro Valley, Arizona. During 1997, petitioner was a full-time employee of Quality Screw & Nut Company (QSN) in its Tucson, Arizona, branch. Petitioner was the general manager of the branch and conducted regular business in Mexico on behalf of petitioner’s main client, McCulloch Corporation (McCulloch). McCulloch, based in Tucson, Arizona, manufactured various power tools including gas and electric chain saws, string trimmers, and blowers. QSN provided supplies, including screws and nuts, and logistics management for 1 Petitioner concedes that he failed to include $24 of taxable interest received from Capital One Federal Savings Bank and $48 of taxable interest received from DM-Federal Credit Union in 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011