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covered the documents so that the only thing that she saw was a
little check mark and the line for her to sign.
Petitioner essentially argues that while the signatures on
the contract and the fax are hers, as a result of Rego’s actions,
she had no knowledge of the content in either document.
Generally, a taxpayer cannot avoid the duty of filing accurate
returns by placing responsibility on an agent. Pritchett v.
Commissioner, 63 T.C. 149, 174 (1974). Moreover, the Court is
not required to accept petitioner’s self-serving testimony.
Geiger v. Commissioner, 440 F.2d 688 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159; see Transp. Labor Contract/Leasing,
Inc. v. Commissioner, 123 T.C. 154, 187 (2004). To the extent
that respondent has the burden of producing information with
respect to the Form 1099-MISC pursuant to section 6201(d),
respondent has satisfied that burden.
Other evidence weighs in favor of a finding that petitioner
was an independent contractor for ACC in 2003. In 2003,
petitioner lived with her teenage daughter and 85-year-old
mother. Petitioner testified that, in 2003, their income derived
primarily from: (1) Her independent contractor job at STC, with
an annual income of $4,963.51, and (2) her mother’s Social
Security income, with an annual income of approximately $3,600.
On its face, a monthly income of approximately $700 appears
insufficient to provide for a family of three in Miami.
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