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Respondent determined for 2003 a deficiency in petitioner’s
Federal income tax of $3,190. After concessions,1 the issues for
decision are: (1) Whether petitioner received unreported
nonemployee compensation of $14,300, and (2) whether petitioner
worked as an independent contractor subject to self-employment
tax.
Background
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Miami, Florida.
Petitioner is a native Spanish speaker who does not speak or
understand English. Her daughter acted as her interpreter at
trial.
During 2003, petitioner worked as an independent contractor
doing packing work for Selected Trading Corporation (STC).
Petitioner’s job involved opening boxes containing the items,
packaging them, sealing them into bags, and then putting a price
on them. Petitioner packaged items such as hair accessories, and
she was paid on a piecework basis.
1Petitioner concedes: (1) Her correct filing status is
married filing separately; (2) she is not entitled to a
dependency exemption deduction; and (3) she is not entitled to an
earned income credit.
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