T.C. Memo. 2006-44
UNITED STATES TAX COURT
SAMUEL A. COLE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11968-04. Filed March 16, 2006.
Samuel A. Cole, pro se.
Beth A. Nunnink, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $3,494
in petitioner’s Federal income tax for 2001 and an addition to
tax of $35 under section 6651(a)(1). After concessions by
respondent, the issues for decision are:
(1) Whether petitioner was a statutory employee in 2001
under section 3121(d)(3)(D);
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