William H. Mansel, Jr. and Angela W. Mansel - Page 4

                                        - 3 -                                         
          end profits”.  He described the “back-end profits” as relating to           
          purchases by car owners of extended warranties, credit life                 
          insurance, and “gap” insurance (the nature of which was not                 
          described).  Petitioner also advertised in newspapers for his               
          services in obtaining approvals for car loans.                              
               The principal issue in this case is with regard to $13,500             
          in commissions paid to petitioner by the car dealer, Victory                
          Motors, during 2001.  Petitioner’s engagement with that                     
          dealership was for about 2 months that year.  In that time                  
          period, petitioner received $13,500 in commission payments from             
          Victory Motors.  For some time, petitioner had encountered                  
          difficulties in having his earned commissions paid to him, and,             
          after approximately 2 months in 2001, petitioner terminated his             
          relationship with Victory Motors and went to work for another               
          automobile dealer.  At the time he left, petitioner had received            
          a total of $13,500 in commissions from Victory Motors.  No                  
          further commissions were paid by Victory Motors to petitioner.              
               On their joint Federal income tax return for 2001,                     
          petitioners did not include or report as income the $13,500 in              
          commissions petitioner received that year.  In the notice of                
          deficiency, respondent determined that the commissions                      
          constituted gross income.  Respondent also determined that these            
          commissions represented self-employment income, and the                     
          deficiency included $362 as self-employment taxes under section             

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011