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Petitioner reported her work hours on a weekly time card,
listing the duties performed and time spent completing each task.
Petitioner submitted the time card to Mr. Dixon and was paid for
hours in excess of the required 15 hours work week. Petitioner
resided in the residence and provided services for Mr. Dixon for
15 weeks.
Petitioner was not completely satisfied with her living
arrangements and decided to terminate the relationship at the end
of the semester. After providing Mr. Dixon with the appropriate
notice, petitioner moved out of the residence in December 1999.
For the 1999 tax year, Mr. Dixon, under the name “DIX-EN (A
Partnership)”, issued a Form 1099-MISC, Miscellaneous Income
(Form 1099), to petitioner under the name Cheryl Gomez. The Form
1099 reported nonemployee compensation of $3,914.15 and contained
a note that $3,375.00 of the compensation was associated with a
nontaxable barter transaction.
Petitioner testified that she never received a Form 1099
from Mr. Dixon prior to petitioners’ filing their 1999 tax
return. After receiving the notice of deficiency, petitioner
contacted Mr. Dixon and received a copy of the Form 1099 and an
accompanying calculation worksheet.
The worksheet detailed the calculation used to determine the
total amount reported on the Form 1099. The worksheet consisted
of a separate calculation for the room, the board, and the funds
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