- 4 - Thereafter, respondent sent to petitioners a letter in accordance with Branerton Corp. v. Commissioner, 61 T.C. 691, 692 (1974) (Branerton letter), suggesting a conference between the parties and requesting information and documentation in support of the positions taken by petitioners on their return. With respect to petitioners’ claim that petitioner should be classified as an independent contractor, respondent identified as possible supporting materials billing records for patients treated outside of DWP, employment contracts, business licenses, business cards, advertising, yellow pages listings, accounting records, and so forth. As regards the claimed expenses, requested items included receipts, invoices, ledgers, journals, etc., showing that the amounts were actually paid or incurred and were ordinary and necessary business expenses. Respondent in the Branerton letter also conceded certain adjustments reflected for 1997 in the notice of deficiency, primarily related to self- employment income and taxes. Petitioners neither attended the proposed meeting nor contacted respondent prior to the suggested date. A letter from Mr. Judge was apparently thereafter sent to the Internal Revenue Service and indicated that petitioners were in Ireland and were suffering from medical difficulties. Petitioners did not at that juncture, nor at any time since, produce the corroborating materials suggested by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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