- 4 - 2001. In her petition, petitioner contends that she is entitled to the Schedule C expense deductions because she is a statutory employee under section 3121(d)(3). At the time of filing, petitioner resided in Nashville, Tennessee. Upon receipt of the petition this Court promptly informed William De Montbreun that he could not be recognized as counsel of record because he was not admitted to practice before the Tax Court and that all communication would be directed to petitioner. Respondent filed an Answer on July 17, 2001. Petitioner then sent a letter, dated July 18, 2001, to the Court affirming her petition. The Court treated the letter as an Amendment to Petition and filed it on July 23, 2001. Respondent then filed an Answer to Amendment to Petition on August 8, 2001. After the issues had been joined, Appeals Officer Elaine Rhoton contacted petitioner to arrange for a conference and then met with petitioner’s representative, Mr. De Montbreun. At this meeting on October 16, 2002, Appeals Officer Rhoton reviewed the information provided relating to petitioner’s employment status during 1998, including a letter dated June 26, 2001, and written by Daryl Neville, Human Resources Representative of Arch Wireless (fourth letter). The fourth letter, which previously had not been shown to any representative of respondent, confirmed petitioner’s employment and stated, in part: Jennifer Rusley * * * was employed by Arch Communications from July 15, 1997 through October 9,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011