- 3 - reimbursed to some extent, petitioner was told that they did not “know what degree * * * whether 60 or 70 percent.” NSBE’s records show that petitioner received two payments during 1998 and 1999. The first, a $6,000 payment dated October 23, 1998, was labeled as a payment for “Commissions”. The second, an $8,000 payment dated February 18, 1999, was labeled as a payment for “Commission 97-98". The latter payment is the payment at issue in this case. NSBE issued a Form 1099-MISC, Miscellaneous Income, to petitioner for taxable year 1999. This form reflected nonemployee compensation of $8,000. Petitioner filed an individual Federal income tax return for taxable year 1999. Petitioner did not report as income any portion of the $8,000 payment which he received from NSBE, despite his assertion at trial that a portion of this payment was for nonemployee compensation rather than a reimbursement of educational expenses. In the statutory notice of deficiency, respondent determined that the entire $8,000 was includable in petitioner’s gross income and subject to self-employment income tax. Petitioner argues that, while a portion of the $8,000 was indeed nonemployee compensation, the bulk of the payment was a reimbursement of his educational expenses--which he refers to asPage: Previous 1 2 3 4 5 6 7 8 9 Next
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