Edward Charles Jones - Page 3

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          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      
               Respondent determined a deficiency of $1,939 in petitioner’s           
          Federal income tax for 1998.  After concessions by petitioner,              
          the issue for decision is whether petitioner was an employee or             
          an independent contractor in connection with the performance of             
          services during 1998.2  The issue involves the question whether             
          petitioner’s home office expenses are deductible as trade or                
          business expenses on Schedule C, Profit or Loss From Business, as           
          petitioner claimed, or as unreimbursed employee business expenses           
          on Schedule A, Miscellaneous Itemized Deductions, as respondent             
          determined in the notice of deficiency.                                     
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are made part hereof.                    
          Petitioner’s legal residence at the time the petition was filed             
          was Horseshoe Bay, Texas.                                                   
               Petitioner has a college degree in electrical engineering.             
          During his career, he worked for General Electric Corp. and IBM             
          Corp. (IBM).  Although he started as an electrical engineer, he             
          rose to the level of senior engineer/technical management by                
          1970.  He worked for IBM for 28 years.  Part of his work for IBM            

               2    Petitioner conceded issues relating to a passive                  
          activity, deductions for real property taxes and home mortgage              
          interest expense, “other income”, and various computational                 

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