- 3 - Petitioner was associated with or employed by W.H.Y., and performed what he describes as “quality control” services. Petitioner’s relationship to W.H.Y. during 1992 is less than certain because, as noted, the corporation had been dissolved the previous year. During 1992, petitioner was involved with a renovation project for a house that had been damaged by fire. The cost of some or all of the renovations was paid by State Farm Fire and Casualty Company (State Farm). In connection with the renovations, State Farm issued a check for $18,587 payable to petitioner “DBA WHY Construction”, which payment was reported on a Form 1099-MISC, Miscellaneous Income. Dunn Construction Company (Dunn) also issued a Form 1099-MISC reflecting a payment of $16,125 to petitioner for 1992. No other background information regarding this latter payment is included in the record. The above-referenced Forms 1099-MISC issued by State Farm and Dunn are subsequently referred to as the Forms 1099. Apparently, respondent received the information reported on the Forms 1099 but had no record of petitioner’s 1992 Federal income tax return. Sometime during 1998, a revenue officer employed by respondent’s Collection Division contacted petitioner. After discussing the situation with petitioner and confirming that petitioner had not previously filed a 1992 Federal income tax return, the revenue officer preparedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011