- 7 - 25, 1998. Although PSEG Global’s records reflect payments to petitioner in 1998 totaling $159,629, PSEG Global issued petitioner a Form 1099-MISC on which it reported payments to petitioner totaling $168,598 during that year. Petitioner ceased working on behalf of PSEG Global in 1999. During 1998, petitioner maintained at least two bank accounts in the United States. The first was maintained under the name of OU at Wells Fargo Bank, and the second was maintained under the names of petitioner and M. Cristina A Robles at Home Savings of America. Amounts totaling $269,767 were deposited into the first account, and $55,389 was deposited into the second account.1 Petitioner filed a Schedule C, Profit or Loss From Business, with his Federal income tax return for taxable year 1998. This schedule named petitioner as the proprietor of a business engaged in “international business consulting”. The schedule listed the name of the business as “NAFTA”, and it provided an address in Mexico City. Neither party addressed the use of petitioner’s corporation’s name on the Schedule C. Based on petitioner’s testimony and other evidence in the record, we conclude that the 1The total deposit amounts are those reflected in the bank deposit summaries prepared by respondent. Respondent calculated the amount of the deposits using the account statements provided by petitioner. Several of these statements were not available, leaving gaps of approximately 2 weeks with respect to Wells Fargo Bank and approximately 6 weeks with respect to Home Savings of America. Respondent based his determination solely on the time periods for which bank statements were available.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011