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confirmed that his online resume and Web site were in existence
in 2001 and remained in existence as of the date of trial.
Terry acknowledged that in 2001 he had provided computer
services for both Dollarhide and Lincoln, but, generally, he
denied that he had received compensation for his services.
Respondent provided copies of checks issued by Dollarhide to
Major Computer Services and a copy of the Dollarhide general
ledger showing the same check amounts issued to Terry Major as
the vendor. Julie Yows, director of operations for Dollarhide,
testified that in 2001 Dollarhide paid Terry for computer
services rendered and issued him a Form 1099-MISC for 2001
reflecting total compensation of $18,407.94. Terry admitted that
when he received the notice of deficiency claiming he received a
Form 1099-MISC from Dollarhide, he did nothing to investigate
what he apparently contended was an error by Dollarhide.
Louise was not present at trial. Although respondent, in an
opening statement, referenced the deficiency and addition to tax
for Louise, Terry did not address any items respondent listed in
the notice of deficiency with respect to Louise.
Respondent presented as evidence the declaration of Donna
Cooper, an employee in the tax department at Lincoln National
Corporation which together with its affiliates is known as
Lincoln Financial Group. Accompanying Ms. Cooper’s declaration
was a duplicate of the original Form 1099-MISC which Lincoln
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Last modified: May 25, 2011