Thomas N. Coccia - Page 12

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               Petitioner was paid for brokering security services.  He               
          says he served as a middleman and did not realize any profit from           
          this one-time assignment because all the revenue he received was            
          paid out to the workers.  Petitioner had hoped that this                    
          assignment would result in subsequent security jobs, but such was           
          not the case.  Petitioner, however, does not have any records               
          documenting any deductible expenses he may have paid.  Therefore,           
          the Court holds that petitioner is liable for self-employment tax           
          on the income he earned providing the security services.                    
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

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Last modified: May 25, 2011