Stephen J. Major - Page 8

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          show that these payments were related to “other” reimbursable               
          business expenses and not commission or other income from QSN.              
          Respondent presented extensive business records that petitioner             
          submitted to QSN’s headquarters to substantiate his expenses                
          which were reimbursed.  Petitioner suggests that there are other            
          records available at the branch level which could support his               
          contentions; however, he failed to introduce any of them at                 
               We note that the $2,000 monthly checks were paid regularly             
          and did not vary in amount from month to month, whereas the                 
          employee expense reimbursement checks fluctuated by date and by             
          amount depending on the expense report submitted for that period.           
               Without any corroborative evidence, we find that petitioner            
          failed to show that the $24,000 received from QSN during 1997 was           
          a reimbursement of employee expenses.  Accordingly, the $24,000             
          received from QSN is includable in gross income and properly                
          reported as “other income” on petitioner’s 1997 Form 1040.                  
          Self-Employment Tax                                                         
               Section 1401 imposes a tax on an individual’s self-                    
          employment income.  Self-employment income is defined as “net               
          earnings from self-employment”.  Sec. 1402(b).  The term “net               
          earnings from self-employment” is defined as an individual’s                
          gross income from a trade or business carried on by such                    
          individual, less the deductions attributable to such trade or               

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