- 4 -
the training period ahead of schedule and became a MetLife
employee on August 26, 2002.
During the training period, petitioner received payments
totaling $2,160 from MetLife. He received an additional payment
of $3,845 in September 2002. Petitioner acknowledges receiving
these payments. MetLife’s business records indicate the payments
represent petitioner’s earnings during the training period.
For the taxable year 2002, MetLife issued petitioner both a
Form 1099-MISC, and a Form W-2, Wage and Tax Statement. A letter
from a MetLife attorney explains that the Form 1099-MISC
represents petitioner’s earnings as an independent contractor
during the training period, whereas the Form W-2 represents
petitioner’s wage income after he became a MetLife employee. The
Form 1099-MISC reports nonemployee compensation of $6,005,
representing the sum of the $2,160 and $3,845 payments. The Form
W-2 reports wage income of $12,764, which is not in dispute.
Petitioners did not receive the Form 1099-MISC or report the
$6,005 as income. The Form 1099-MISC lists an address in Salem,
Oregon, where petitioners lived during the training period.
Petitioners did receive the Form W-2, which lists an address in
Springfield, Oregon, where petitioners lived when they filed
their 2002 tax return. Petitioners attached the Form W-2 to
their tax return. They also attached Forms W-2 from three other
payors, each of which lists the address in Springfield, Oregon.
After petitioner received respondent’s notice of deficiency,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011