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year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
The issues for decision are: (1) Whether petitioner failed
to report nonemployee compensation of $21,552 for the 2000
taxable year and (2) whether petitioner is liable for the
resulting accuracy-related penalty under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the related exhibits are incorporated
herein by this reference. At the time of filing the petition,
petitioner resided in Baltimore, Maryland.
During the year in issue, petitioner was a heavy collision
technician at Automotive Emporium. He brought his own toolbox
and used his own tools to “rebuild wrecks” and to perform
automobile bodywork. Automotive Emporium issued petitioner a
Form 1099-MISC, Miscellaneous Income, reporting nonemployee
compensation of $21,552 for the 2000 taxable year. The record
includes 48 checks totaling $20,167.55 that were issued by
Automotive Emporium, made payable to petitioner, and dated from
February 3 to October 5, 2000.
JJ Auto Body and Clarksville Auto Center each issued
petitioner a Form W-2, Wage and Tax Statement, reflecting wages
totaling $6,494 for the 2000 taxable year.
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