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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined deficiencies in petitioners’ Federal
income taxes as well as accuracy-related penalties as follows:
Penalty
Year Deficiency Sec. 6662(a)
1999 $17,096 $3,419
2000 16,469 3,294
After petitioners’ concessions,2 the issues for decision
are: (1) Whether Matthew Hudack (petitioner) was a statutory
employee for 1999 and 2000 (years in issue); and (2) whether
petitioners are liable under section 6662(a) for accuracy-related
penalties for the years in issue.
Adjustments to the amounts of petitioners’ itemized
deductions and the alternative minimum tax are purely
computational matters, the resolution of which depends on our
disposition of the first disputed issue.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and the accompanying exhibits.
At the time that the petition was filed, petitioners resided
in Santa Ana, California.
2 For 1999, petitioners concede that they are not entitled
to claimed “business promotion” expenses of $974 and “client
costs” expenses of $402.
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Last modified: May 25, 2011