- 2 - 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 spacklePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011