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issue; (2) whether petitioner is liable for the self-employment
tax for the years in issue; (3) whether petitioner is entitled to
a dependency exemption deduction for one of his daughters for the
years in issue; and (4) whether petitioner is liable for the
addition to tax under section 6651(a)(1)2 for failing to timely
file Federal income tax returns for the years in issue.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts, the supplemental stipulation
of facts, and the attached exhibits are incorporated herein by
this reference. Petitioner resided in La Grande, Oregon, at the
time he filed his petition.
During 1996, petitioner worked as a pipe layer and equipment
operator in Eugene, Oregon. Petitioner initially performed this
work as a consultant and then as an independent contractor.
Petitioner received compensation for services of $38,000 in the
taxable year 1996. During 1997, 1998, and 1999, petitioner
worked for Blue Mt. Conservative Baptist Association’s Camp
Elkanah as a groundskeeper/maintenance supervisor. During these
years, petitioner performed his work as an independent
contractor. Petitioner received compensation for services of
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011