- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011