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Bell worked for him part time passing out brochures and bringing
in referrals throughout 1999 and 2000. Petitioners offered into
evidence copies of a completed Form 1096 for both 1999 and 2000
that listed nonemployee compensation to Mr. Bell of $4,000 for
1999 and $4,800 for 2000.
Respondent disallowed deductions for the amounts Mr. Booker
claimed to have paid Mr. Bell because the Social Security
Administration, with which Forms 1096 would have been filed, has
no information on record of such payments to Mr. Bell for the
years 1999 and 2000. Moreover, respondent averred that the
records of the Social Security Administration show that the
Social Security number listed as belonging to Mr. Bell does not
exist. Also, although the Social Security Administration had a
record of all other employees for whose wages petitioners claimed
deductions for 1999 and 2000, it had no record of a Form 1099
being issued by petitioners to Roy C. Bell or to a person of
another name with the Social Security number petitioners listed
6(...continued)
was entitled to as an additional wage expense deduction actually
pertained to another employee, Eric S. Williams. Mr. Booker
stated that he forgot to deduct wages paid to Mr. Williams during
1999 on his 1999 income tax return. The copy of the Form 1096
for 1999 petitioner admitted into evidence listed both Mr. Bell
and Mr. Williams as wage earners during 1999. In conceding the
entire $13,300 wage deduction for 1999, respondent stated the
intention to allow a deduction for wages paid to Mr. Williams
while disallowing any wage expense deduction pertaining to Mr.
Bell. Therefore, respondent also conceded at trial an additional
$525 deduction as a wage expense, leaving only $4,000 of the
additional $4,525 petitioners sought to deduct for 1999 in
dispute.
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