Calvin L. Eubanks - Page 4




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               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 prepared                     






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