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contractor providing navigational services and, in particular,
training NOAA employees at the U.S. Coast Guard branch facility
at Silver Spring, Maryland. Petitioner was not engaged with NOAA
as an employee. His relationship was based on a contract for
training new employees, preparation of manuals, desk reference
guides, and other navigational matters used by such employees.
Petitioner was not required to be at NOAA offices on a daily
basis and was allowed to prepare his manuals, guides, and other
contract requirements at home. The time petitioner spent at NOAA
facilities was to train employees. However, NOAA made available
to petitioner at all times office space and equipment necessary
for him to perform his services under the contract. Petitioner
estimated that during the year at issue, he was at NOAA
facilities between 35 and 40 percent of the time for the training
of NOAA employees. The remainder of his time was spent at home
where he performed his other obligations under the contract
(preparing training manuals, etc.). None of the training
activities took place at his home.
Petitioner’s contract with NOAA was obtained by bid. He was
paid by the hour. For the year at issue, petitioner contracted
to perform 976 hours of work which translated to 122 work days.
The compensation for that amount of time was $30,256.3
3 On his income tax return for the year at issue,
petitioner reported $35,222 of income from NOAA. There is no
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