Frederick Douglas Abdullah - Page 3

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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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