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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a $6,717 deficiency in petitioner’s1
2001 Federal income tax and a $1,977 penalty pursuant to section
6662(a). In his answer, respondent asserted an increased
deficiency totaling $7,398 and a reduced section 6662(a)
accuracy-related penalty of $1,480.
The issues remaining for decision are:2 (1) Whether amounts
petitioner received from various third parties (principals)
represent wages paid as an employee or payments as an independent
contractor; (2) whether petitioner is entitled to claimed
deductions either as miscellaneous itemized deductions (employee)
or as Schedule C, Profit or Loss From Business, expense
deductions (independent contractor); and (3) whether petitioner
is liable under section 6662(a) for an accuracy-related penalty.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation and supplemental stipulation of facts and
the attached exhibits are incorporated herein by this reference.
1 A joint 2001 Federal income tax return was filed and the
notice of deficiency was issued to Frederick and S. Ghaswala
Abdullah. The petition was filed only by petitioner Frederick
Douglas Abdullah.
2 Petitioner agreed that he did not report $255 in interest
income received in 2001.
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