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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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