Douglas G. Turnidge - Page 3

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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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