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New Dimensions Distribution Services (“New Dimensions”), (2)
whether New Dimensions withheld Federal income tax with respect
to petitioner’s unreported compensation income, and (3) whether
petitioner’s unreported compensation income constitutes self-
employment income subject to the tax imposed by section 1401.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect at relevant times, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Some of the facts have been stipulated and are so found.
When they filed their petition, petitioners resided in Pompton
Lakes, New Jersey.
Petitioner was employed as a full-time dispatcher by New
Dimensions, a New Jersey long-haul trucking company, from January
9 through August 27, 1999. Thereafter, under somewhat different
circumstances, petitioner also performed services as a dispatcher
for New Dimensions between August 28 and December 31, 1999.
Petitioner’s duties as a dispatcher included procuring loads to
be hauled, scheduling pickups and deliveries, and monitoring the
progress of the company’s trucks. Petitioner also performed
miscellaneous office work for New Dimensions. The terms under
which petitioner performed services for New Dimensions never were
set forth in a written agreement.
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Last modified: May 25, 2011