Frederick M. and Cheryl A. Prouty - Page 5




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          wages of $7,914, an increase in nonemployee compensation of                 
          $1,160, a disallowance of the claimed $766 credit for excess                
          Social Security and RRTA tax withheld, and computational                    
          adjustments.                                                                
               On February 13, 2001, the Ogden Service Center received a              
          faxed copy of a letter "To Whom It May Concern", stating that               
          petitioner "was a 100% commissioned Account Executive for                   
          Sullivan Broadcasting"1 from November 1989 to June 1998.                    
               On March 9, 2001, the Ogden Service Center received a                  
          "Transfer To Appeals Request" signed by petitioners, requesting             
          that their case be transferred to the Appeals Office in                     
          Nashville, Tennessee.  The Ogden Service Center sent to                     
          petitioners a revised notice of tax changes dated March 20, 2001,           
          proposing the allowance of the claimed $7,904 of deductions on              
          petitioner's Schedule C.  Petitioners met with their accountant             
          on March 23, 2001, to discuss the proposed tax changes sent to              
          them on March 20, 2001.                                                     
               The petition in this case was filed on May 8, 2001, and                
          respondent filed the answer on June 29, 2001.  On July 2, 2001,             
          the case was assigned to an Appeals officer for consideration.              
          The Appeals officer, on August 23, 2001, met with petitioner and            
          her accountant who stated that although Mr. Prouty had failed to            


               1There is no explanation in the record as to whether                   
          "Sullivan" broadcasting is the same company as "Sinclair                    
          Television of Nashville" as listed on the W-2.                              





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