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received wage income of $800 in 1997 and $3 in 1998. The
relationship of Mr. Radnitz with the film and television industry
for whom his writings were created and sold was that of an
employee and was not an independent contractor relationship.
Respondent does not challenge that characterization.
Accordingly, the moneys Mr. Radnitz received for his work
products were reflected on Forms W-2, Wage and Tax Statement.
Screenwriters are generally not provided office space in
which to do their writing. They are expected to provide their
own offices. As a result, during the years at issue, Mr. Radnitz
provided himself with office space for his compositions. The
type and location of the spaces depended on various factors,
including cost, convenience, the length of the writing project,
and the need for privacy and quiet. For the majority of the
time, Mr. Radnitz used his residence as an office. However, for
two 3-month periods during 1998, he used rented spaces that were
outside of his main residence.
During 1997, Mr. Radnitz spent most of his time writing a
screenplay entitled "Home Again". His office was exclusively at
his residence at the Vista Loma address for the first part of the
year and at the Deepak address in the latter part. In 1998, Mr.
Radnitz used the office at the Deepak residence in January and
February, again from June through August, and in December. From
March through May 1998, he used a rented apartment on North
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