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Credit financed equipment purchases. Petitioner would refer a
purchaser of equipment to Key Credit, and, if the financing were
approved, petitioner would get a nominal percentage of the profit
on the financing. According to Emelio Salinas, petitioner’s
contact with Key Credit, the maximum amount petitioner could have
made under the arrangement would have been $2,000 to $5,000 per
year. Key Credit treated petitioner as an independent contractor
and issued her Forms 1099 for 1999 and 2000.
Key Credit did not require that petitioner travel, and she
was informed that Key Credit would not reimburse her for any
travel expenses she incurred. The travel expenses shown on the
Schedules C allegedly were incurred by petitioner in connection
with her association with Key Credit. With respect to the car
expenses, petitioner did not maintain a log or other record of
mileage. With regard to the travel and meal expenses, petitioner
introduced receipts which consist of copies of a round trip air
travel itinerary for Mr. Brittain and petitioner to Columbus,
Ohio, in 2000 of $406, a round trip air travel itinerary for
petitioner to Buffalo, New York, in 2000 of $218 to meet with Mr.
Brittain, a hotel receipt from Columbus, Ohio, of $231, and a
ticket stub to a concert in Columbus, Ohio, of $61. The
deductions for utilities allegedly are derived from the utility
expenses at petitioners’ personal dwelling.
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Last modified: May 25, 2011