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Petitioner filed her 1999 Form 1040, U.S. Individual Income
Tax Return with the Philadelphia Service Center of the Internal
Revenue Service on April 15, 2000. Petitioner reported the
income she received from the State Department under the personal
service contracts as wages in conformity with the Form W-2 issued
by the State Department. Petitioner deducted the $8,638
contribution to her simplified employee pension on the 1999
return. Petitioner attached to the 1999 return an explanation of
the contribution to her simplified employee pension. On that
statement she asserted that the Form W-2 did not accurately
reflect her employment status with the State Department and
stated that she was an independent contractor.
On June 13, 2003, respondent issued a notice of deficiency
to petitioner for 1999 determining a $2,571 deficiency resulting
from the disallowance of petitioner’s deduction for the $8,638
contribution to her simplified employee pension for 1999. The
notice of deficiency explained that the deduction for the
contribution to petitioner’s simplified employee pension was not
allowed because petitioner had not established that she was
“entitled to this deduction”.
Petitioner timely filed a petition in this Court for
redetermination of the deficiency.
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