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Box 15, which indicates "statutory employee" status, was not
checked on any of the Forms W-2. Total wages reported on line 7
of the Form 1040 were $45,419.
Petitioner filed with her return a Schedule C. The Schedule
C reported business income of $45,419, expenses of $11,506, and
net profit of $33,913.
Respondent sent to petitioner a statutory notice of
deficiency for tax year 2000 determining that petitioner is
liable for self-employment tax and is entitled to a deduction for
one-half that amount.
Big Train, Inc.
Petitioner was hired in January 2000 by Big Train, Inc. (Big
Train), as their northern California sales representative.
Petitioner's employment with Big Train was terminated in August
2000. During this period, petitioner's responsibilities included
outside sales and support for new and existing customers as well
as achieving the revenue growth and new store goals set by the
company.
Peerless Coffee Co.
From about October through December 2000, petitioner worked
for the Peerless Coffee Co. (Peerless) By letter dated September
26, 2000, Peerless offered petitioner employment on their sales
team. The letter sets forth petitioner's salary and commission
and the availability of health benefits after the completion of a
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