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The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, Ronald McLean (Mr. McLean), doing business
as Ronald McLean Eastern Video, resided in College Park, Georgia.
FINDINGS OF FACT
During the quarters at issue, petitioner operated as a sole
proprietorship. It operated as a video rental business from two
locations in Atlanta, Georgia, under the name Eastern Video. Mr.
McLean filed a Form 1040, Individual Income Tax Return, for 1996
with a Schedule C, Profit or Loss From Business, in the name of
Eastern Video. Among the items of expense reported on the
schedule were “contractual services” of $26,160 and wages of
$60,706.
Petitioner issued Forms W-2, Wage and Tax Statement, to
three employees, Gladys Favors, Angela Trimble,2 and Kevin
Walton, for wages totaling $50,544 for 1996. It also filed Forms
941, Employer’s Quarterly Federal Tax Return, and a Form 940,
Employer’s Annual Federal Unemployment (FUTA) Tax Return, for
1996 reporting total wages of $50,544 paid to employees. The
three full-time employees performed whatever duties were required
to run the video stores.
2 The stipulation of facts refers to her as Angela “Halsey”
while the associated exhibit refers to her as Angela “Trimble”.
There is no explanation in the record for this discrepancy.
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