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(3) whether petitioner is liable for an addition to tax
under section 6654 for failing to make estimated payments with
respect to his 2000 tax liability.
FINDINGS OF FACT
Petitioner resided in Longwood, Florida, when his petition
in this case was filed.
During 2000, petitioner, a certified registered nurse
anesthetist, contracted with and provided services as an
independent contractor for Nationwide Anesthesia Services, Inc.
(Nationwide). Petitioner submitted invoices for his services,
which showed the date and hours worked as well as related
expenses and the total amount due to him under his contract with
Nationwide. During 2000, petitioner also worked as an employee
for Wellmont Health System for which he was paid wages totaling
$23,012.95, and he requested and received an early withdrawal of
$50,000 from an employer-sponsored retirement account at the
Variable Annuity Life Insurance Company (VALIC) from which
Federal income tax of $10,000 was withheld.
Petitioner did not file a Federal income tax return or make
any estimated tax payments for 2000. On September 26, 2003,
respondent issued a notice of deficiency for 2000 determining
that petitioner received wage income of $23,012, nonemployee
compensation of $171,069, and an early IRA distribution of
$50,000. In the notice of deficiency, respondent also determined
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