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by the business committee of the Oneida Tribe. In her capacity
as a judicial officer, she heard disputes between the Oneida
Tribe and its employees. The hearings were conducted at various
locations to which Mrs. Doxtator traveled at her own expense.
Her decisions were binding on the Tribe and its employees. She
controlled her own schedule and heard as many or as few cases as
she chose. She received a $125 stipend per case heard,
regardless of its duration.
Mrs. Doxtator received $23,480, $22,450, and $13,550 in
1997, 1999, and 2000, respectively, as compensation for her
services as a judicial officer from the Oneida Tribe. The Oneida
Tribe issued Forms 1099-MISC, Miscellaneous Income, reporting
these payments to Mrs. Doxtator in each year. Petitioners did
not report on their 1997, 1999, or 2000 return, nor pay self-
employment taxes with respect to, the foregoing amounts received
by Mrs. Doxtator. Respondent determined that the foregoing
amounts were subject to income and self-employment tax.
Native American Finance
Petitioners attached to their 1997 and 2000 returns a
Schedule C, Profit or Loss from Business, for an undertaking
called "Native American Finance". According to Mr. Doxtator, the
Native American Finance business consisted of Mr. Doxtator's
activities in contacting Native American tribes to advise tribal
leaders of a revenue ruling that he believed eliminated liability
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Last modified: May 25, 2011