Kevin and Bridget Naughton - Page 1
















                                 T.C. Memo. 2002-222                                  


                               UNITED STATES TAX COURT                                


                     KEVIN AND BRIDGET NAUGHTON, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 10731-00.             Filed September 4, 2002.              

                    For 1996 and 1997, Ps K and B filed with their                    
               joint tax returns Schedules C, Profit or Loss From                     
               Business, on which they reported income and deducted                   
               claimed expenses related to K’s rendering of medical                   
               services for DWP.                                                      
                   Held:  During 1996 and 1997, K was an employee of                 
               DWP and not an independent contractor.  Ps therefore                   
               are not entitled to report K’s income and expenses on                  
               Schedules C.                                                           
                    Held, further, Ps are not entitled to deduct                      
               business expenses claimed on their 1996 and 1997                       
               returns.                                                               
               Kevin and Bridget Naughton, pro sese.                                  
               Michael S. Hensley, for respondent.                                    








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