Andrew S. Cirbo - Page 3

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          reviewable by any other court, and this opinion shall not be                
          treated as precedent for any other case.                                    
               Respondent determined for 2003 a deficiency in petitioner’s            
          Federal income tax of $11,385 and a section 6662(a) accuracy-               
          related penalty of $2,277.  The issues for decision are whether             
          petitioner:  (1) Received unreported nonemployee compensation in            
          2003, (2) is subject to self-employment tax, and (3) is liable              
          for a section 6662(a) accuracy-related penalty.                             
               The stipulated facts and the exhibits received into evidence           
          are incorporated herein by reference.  At the time the petition             
          in this case was filed, petitioner resided in Centennial,                   
               During 2003, petitioner was an insurance agent licensed in             
          Colorado.  In February of 2003, petitioner was approached by                
          Patrick Donlon (Donlon) who at that time was organizing a                   
          Colorado entity called Secure Investments and Planning, LLC                 
          (Investments).  Investments did not employ a licensed insurance             
          agent because its primary focus was the mortgage business.                  
               Donlon asked petitioner whether he would be willing to be              
          the agent of record at North American Company for Life and Health           
          Insurance (NACOLAH) for Investments, in the event that                      
          Investments wanted to sell products associated with life or                 

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