- 2 - decision are: (1) Whether petitioner is liable for income tax on her wages and unemployment benefits; (2) whether petitioner is liable for the addition to tax of section 6651(a)(1); and (3) whether petitioner is liable for the addition to tax of section 6651(a)(2). FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner resided in Miami, Florida, when she filed her petition. During 2003, petitioner worked as a seamstress for Mimi Enterprises, Inc. (Mimi’s), a retail bridal gown shop. Mimi’s paid petitioner $11,210 for her work there during 2003. During 2003, Mimi’s classified petitioner as an independent contractor and did not withhold income or employment taxes from its payments to petitioner. Petitioner also received unemployment compensation in the amount of $208 from the Florida Agency for Workforce Innovation (FAWI) in 2003. Petitioner did not file a Federal income tax return for 2003, and petitioner’s only payment toward her income tax liability was the $21 that FAWI withheld from her unemployment compensation. On or about January 14, 2005, respondent filed a 1(...continued) the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007