- 7 - 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 orPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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