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MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a $7,411 deficiency
in and a $1,457 penalty pursuant to section 66622 on petitioner’s
2000 Federal income tax. After concessions,3 the issues for
decision are: (1) Whether during 2000 petitioner received
$29,490.83 in income from Dynamex Operations East, Inc.
(Dynamex); and (2) whether petitioner is liable for the section
6662 penalty for 2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The oral stipulation of facts and the referenced exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Claycomo, Missouri.
During 2000, petitioner worked for Professional Express,
Inc. (PEI), and Dynamex. During 2000, petitioner received wage
income of $1,414.56 from PEI, and he received income of
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
3 Petitioner conceded that during 2000 he received
$1,414.56 in wage income from Professional Express, Inc. At
trial, petitioner failed to address respondent’s self-employment
tax determination with respect to income from Dynamex, other than
to dispute receiving the amount subject to self-employment tax.
Petitioner failed to file any briefs. Accordingly, the
application of self-employment tax is computational.
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Last modified: May 25, 2011