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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.
Background
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,
Colorado.
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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