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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,
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Last modified: May 25, 2011