George A. and Hilda Quintero - Page 7

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          petitioner’s earnings from AAA amounted to $6,350 (computed by              
          subtracting gifts from family members plus the income earned by             
          Mrs. Quintero reported on their 1997 return from the total                  
          deposits made to the checking account).                                     
               We consider petitioners’ various claims as to the amount of            
          income petitioner earned during 1997 against the amount reflected           
          on AAA’s records.1  The accuracy of AAA’s monthly payroll                   
          records, although not beyond question, is supported by the                  
          pattern of deposits into petitioner’s checking account.  All                
          things considered, we find AAA’s records more reliable than                 
          petitioners’ various and inconsistent claims as to the amount of            
          compensation that petitioner received from AAA during 1997.                 
          Accordingly, respondent’s determination that petitioner earned              
          and received compensation totaling $23,552 from AAA during 1997             
          is sustained.                                                               
          2.   Self-employment tax                                                    
               In addition to the income tax imposed by section 1, section            
          1401(a) imposes a tax upon a taxpayer's self-employment income.             
          Disregarding irrelevant exceptions, "self-employment income" is             
          defined as "net earnings from self-employment", which, in turn,             
          is defined as "the gross income derived by an individual from any           

               1 We note that at trial respondent did not exclusively rely            
          upon the Form 1099.  AAA’s payroll records as well as the                   
          testimony of the person responsible for maintaining those records           
          were also admitted into evidence.  See sec. 6201(d).                        

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