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During the years in issue, petitioner never requested from
ECI a Form W-2, and petitioner never objected to ECI’s use of
Forms 1099 to report to respondent petitioner’s gross earnings.
For 1999 through 2002, petitioner did not make estimated
Federal income tax payments to respondent, and petitioner did not
file Federal income tax returns.
On audit, respondent treated petitioner as an independent
contractor of ECI, determined petitioner’s income and deductions
relating to petitioner’s truck driving activity, and determined
petitioner’s taxable income and petitioner’s income and self-
employment taxes.
In respondent’s determination of petitioner’s income,
respondent utilized the Forms 1099 ECI had submitted, and
respondent allowed business expense deductions for petitioner’s
truck lease payments to CCI. Respondent also analyzed
petitioner’s bank accounts and concluded that significant
additional unexplained funds had been deposited into petitioner’s
bank account, which unexplained funds respondent treated as
additional taxable income relating to petitioner’s work for ECI
and CCI. Petitioner’s taxable income as determined by respondent
is set forth below:
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Last modified: March 27, 2008