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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
trial.
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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