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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.
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Last modified: November 10, 2007