Richard A. Brunsman - Page 2

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          tax.  After concessions,2 the issues are whether petitioner is              
          liable for the tax on $4,403 of unreported income and the                   
          accuracy-related penalty under section 6662(a).  Petitioner                 
          resided in Orlando, Florida, at the time the petition was filed.            
               Petitioner was employed with Sparks-Piper Exhibits &                   
          Environments, Inc. (Sparks-Piper) until September of 1999 when he           
          started employment with Czarnowski Display Services, Inc.                   
          (Czarnowski).  Petitioner remained an employee of Czarnowski for            
          the remainder of the 1999 taxable year.  Petitioner purchased               
          various business items for Czarnowski, and was reimbursed for               
          those amounts.  During 1999, Czarnowski issued 14 payments to               
          petitioner:  10 payments of $1,500 each and the remaining four              
          payments were in the amounts of $4,600, $2,500, $2,838.18, and              
               Sparks-Piper reported petitioner’s wages of $51,217 on Form            
          W-2, Wage and Tax Statement.  Czarnowski reported nonemployee               
          compensation paid to petitioner of $26,814 on Form 1099-MISC,               

               2  In the notice of deficiency, respondent asserts that                
          petitioner received, but did not report, $26,814 of nonemployee             
          compensation and $550 of unemployment compensation.  Petitioner             
          concedes that he is liable for the tax on $17,214 of                        
          compensation, and the parties concede that petitioner is liable             
          for the tax on $100 of unemployment compensation.  Respondent               
          concedes that petitioner was an employee of Czarnowski, and of              
          the $26,814 petitioner received, $5,197 represents reimbursement            
          for employee business expenses.  Thus, the amount of compensation           
          in dispute is $4,403.                                                       

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