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Techmatics began paying the employer’s share of Social Security
taxes on petitioner’s behalf. However, Techmatics did not
provide any pension plan, major medical insurance, disability
insurance, flexible spending, life insurance, or other benefits
to petitioner. Petitioner traveled extensively and submitted
travel vouchers for reimbursement of travel expenses. After this
administrative change, Techmatics began reporting petitioner’s
compensation, for tax purposes, on Form W-2, Wage and Tax
Statement.
Part of petitioner’s consulting services involved the
technical engineering design and manufacture of what was referred
to as advance signal processors. He also helped implement a
program to assist the Navy in implementing off-the-shelf, rather
than custom-made, computer components. Occasionally on such
projects, petitioner would take a leadership role, working with
Navy project managers and senior engineers. At one point the
Navy provided him with a portable computer for use in his work,
which he returned. Techmatics, by contrast, did not provide any
equipment to petitioner.
Petitioner did not perform any services at Techmatics’
headquarters or offices. His work was performed at home or at
the manufacturing or research sites involved in the Navy
projects. The latter sites included the A&T Laboratory at
Murray, New Jersey, a manufacturing facility in Greensboro, North
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