- 4 - In March 1996, Mr. Kerkinni approached petitioner and informed him that IMC could no longer afford to pay him a salary. Petitioner claims that at that time, he agreed to continue working for IMC without a salary. Petitioner and Mr. Kerkinni agreed that IMC would reimburse petitioner for any expenses he paid in performing his duties as an employee. The reimbursement payments were to be made whenever and in whatever amounts IMC could afford to make them. Mr. Kerkinni also agreed that IMC would purchase any of petitioner’s old tools that were being used by employees of IMC. At Mr. Kerkinni’s request, petitioner kept an inventory list of the tools and equipment owned by him and used by IMC employees and added to the list annually. During 1996, 1997, 1998, and 1999, petitioner paid expenses related to his work at IMC. Petitioner’s expenses included travel and purchases of new equipment. IMC issued checks to petitioner between March and December 1996, and in 1997, 1998, and 1999. The amounts of these checks were not reported to petitioner on a Form W-2, and petitioners did not report the amounts of the checks on their 1996, 1997, 1998, or 1999 Federal income tax returns. The checks from IMC were issued almost every month, although on different days each month. The amounts of the checks varied, from $500 (January 2, 1997) to $4,000 (September 20, 1996), and were generally in round numbers. Petitioner did not receive a statement allocating the amounts of the checksPage: 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