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During the years at issue, petitioner was employed by the
corporation. The corporation was owned and operated by the
Cheyenne River Sioux for purposes of restoring buffalo to tribal
lands. The corporation raised buffalo on tribal land, and the
buffalo were used for various purposes, including slaughter for
tribal and public consumption and sale, and for use in tribal
ceremonial events. Petitioner’s position with the corporation
was director of the buffalo restoration project.
During the years at issue, the corporation paid petitioner
wages for his services as director and reported those wages to
respondent and petitioner via Forms W-2, Wage and Tax Statement.
The corporation deducted withholding tax, FICA tax, and medicare
from petitioner’s wages, and those deductions were also reported
on the Forms W-2. The wages paid by the corporation were
$33,860, $37,105, and $37,600 for 1997, 1998, and 1999,
respectively.
The source of the wages paid petitioner by the corporation
is not clearly described in the record, but the wages are not
exclusively from revenue related to the buffalo restoration
project.
Petitioner also received various other items of income he
concedes are taxable to him during the years at issue and are no
longer in dispute.
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Last modified: May 25, 2011