C. Wayne Lewis, Jr. - Page 2

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                                  FINDINGS OF FACT                                    
               In 1998, petitioner provided services to Highway Master                
          Corp. (HMC) and Saunders-Ream Advertising & Marketing (SRAM).               
          HMC and SRAM paid petitioner $3,920 and $3,140, respectively, and           
          issued him Forms 1099-MISC, Miscellaneous Income, reflecting such           
          compensation.  In that same year, Salomon Smith Barney Inc. (SSB)           
          paid petitioner $235 of dividends and issued him a Form 1099-DIV,           
          Dividends and Distributions, reflecting such dividends.                     
               In 2000, petitioner was employed by Vu Ryte, Inc. (VRI).               
          VRI paid petitioner $34,818 and issued him a Form W-2, Wage and             
          Tax Statement, reflecting this amount and $3,100 of Federal                 
          income tax withheld.                                                        
               In 2001, petitioner continued employment with VRI, received            
          a distribution from VRI’s retirement plan with Merrill Lynch                
          (ML), and was involved in real estate sales with Hexter-Fair                
          Title Co. (HFTC) and Community Title (CT).  VRI paid petitioner             
          $36,332 and issued him a Form W-2 reflecting this amount and                
          $3,312 of Federal income tax withheld.  HFTC and CT paid                    
          petitioner $160,500 and $50,000, respectively, and issued him               
          Forms 1099-S, Proceeds From Real Estate Transactions, reflecting            
          such proceeds.  ML distributed $6,174 to petitioner from his VRI            
          retirement plan and issued him a Form 1099-R, Distributions From            


               1(...continued)                                                        
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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