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Procedure. The decision to be entered is not reviewable by any
other court, and this opinion should not be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax for 1997 of $7,896, an addition to tax under section
6651(a)(1) of $1,974, and an accuracy-related penalty under
section 6662 of $1,579. The issues for decision are: (1)
Whether Barry Mangels (petitioner) had unreported nonemployee
compensation of $27,429; (2) whether petitioner worked as an
independent contractor subject to self-employment tax; (3)
whether petitioners failed to file a timely Federal income tax
return without reasonable cause; and (4) whether petitioners are
subject to an accuracy-related penalty under section 6662.
Petitioners conceded receipt of $11,471 of unreported income.
Petitioners did not dispute or present evidence as to adjustments
in the notice of deficiency increasing interest income and
cancellation of indebtedness income. Accordingly, we deem these
issues to be conceded.
Background
The stipulation of facts and accompanying exhibits are
incorporated herein by reference. Petitioners resided in
Sarasota, Florida, at the time their petition was filed in this
case.
During the second half of 1997, petitioner worked as a
“handyman” on a few projects for John Salvatore Parziale (Sal
Parziale). Petitioner performed tile work, painting, and spackle
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