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$29,490.83 from Dynamex in exchange for services he performed for
Dynamex as an independent contractor.
Petitioner timely filed his Federal income tax return for
2000 (2000 return). Petitioner’s 2000 return contained all zeros
except for $125 listed as Federal income tax withheld, total
payments, amount overpaid, and amount he wanted refunded.
Attached to his 2000 return was (1) a Form W-2, Wage and Tax
Statement, from PEI listing $1,414.56 in wages, (2) a Form 1099-
MISC, Miscellaneous Income, from Dynamex listing $29,490.83 in
nonemployee compensation (Form 1099), and (3) a 2-page document
containing frivolous and groundless arguments regarding why he
was not subject to tax.
On or about June 4, 2001, in response to a letter from
respondent regarding his 2000 tax year, petitioner mailed
respondent a 6-page letter containing frivolous and groundless
arguments regarding why he was not subject to tax.
Respondent issued petitioner a notice of deficiency
determining a $7,411 deficiency and a $1,457 section 6662 penalty
for 2000. The deficiency and penalty were based on the amounts
PEI and Dynamex paid to petitioner in 2000 and corresponding
adjustments for self-employment tax.
Petitioner filed a petition and an amended petition
contesting respondent’s determination. Petitioner designated
Boston, Massachusetts, as the place of trial.
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