Stephen & Dawn Del Monico - Page 4

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          periods between September 3 and December 24, 1999 (referred to              
          herein as the “disputed pay period”).1  During the disputed pay             
          period, petitioner received weekly paychecks of approximately               
          $737.28 for most of the weeks in issue.  However, these                     
          paychecks were drawn from New Dimensions’ general corporate                 
          account and were not processed through Digit.  In contrast to               
          the paychecks issued by Digit, these paychecks were handwritten             
          and issued without pay stubs or any kind of receipt indicating              
          withholding for Federal or State income taxes or other required             
          purposes.  Each paycheck on its face showed that the entire                 
          amount of the check was payable to petitioner and also contained            
          a notation, such as “pay,” “salary,” or “dispatcher” indicating             
          that the check was issued as compensation for services                      
          performed.                                                                  
               New Dimensions reported payment of $12,396 to petitioner               
          during the disputed pay period as nonemployee compensation on a             
          Form 1099 for 1999 and did not include this amount on                       
          petitioner’s Form W-2 for 1999.  According to New Dimensions,               
          petitioner and the company agreed to change petitioner’s status             
          from employee to independent contractor for the disputed pay                




               1The final weekly pay period of 1999 was the pay period                
          ending December 31.  The corresponding pay date for this period             
          occurred in January 2000 and is not considered income earned in             
          1999.                                                                       





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