Lisa Beth Levine - Page 13

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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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