- 2 -
Respondent determined a deficiency in petitioner's Federal
income tax of $4,122 for 2000. After concessions,1 the issues
remaining for decision are: (1) Whether petitioner, during the
year at issue, was a statutory employee under section
3121(d)(3)(D); (2) whether petitioner is liable for self-
employment tax; and (3) whether petitioner is entitled to
deductions for either employee business expenses on Schedule A,
Itemized Deductions, or trade or business expenses on Schedule C,
Profit or Loss From Business, under section 162(a).
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
resided in Oakland, California, at the time the petition was
filed.
Petitioner timely filed her Form 1040, U.S. Individual
Income Tax Return, for 2000. Attached to the return were three
Forms W-2, Wage and Tax Statement, in petitioner's name reporting
wages as follows:
Big Train, Inc. $35,142.29
Peerless Coffee Co., Inc. 9,373.48
George W. Riley Professional
Beauty Center 757.87
1Petitioner conceded at trial that she was not a statutory
employee of her employers George Riley and Victoria's Secret.
Petitioner only worked for Victoria's Secret for only 1 day.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011