- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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