Richard Clarke Randall - Page 3

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          to this amended return 2003 Forms 1099-MISC, Miscellaneous                  
          Income, from National Quality Assurance USA, Inc. and Labtest               
          International, Inc.; on each, petitioner had crossed out the                
          amounts listed in the box labeled “nonemployee compensation” and            
          written in “0”.  He included at the bottom of each of the Forms             
          1099-MISC the following statement:                                          
               This corrected Form 1099-MISC is submitted to rebut a                  
               document known to have been submitted by the party                     
               identified above as “PAYER” which erroneously alleges a                
               payment to the party identified above as the                           
               “RECIPIENT” OF “gains, profit or income” made in the                   
               course of a “trade or business”.  Under penalties of                   
               perjury, I declare that I have examined this statement                 
               and to the best of my knowledge and belief, it is true,                
               correct, and complete.                                                 
               Respondent issued to petitioner the notice of deficiency on            
          September 26, 2005, and petitioner timely filed a petition in               
          this Court.  In the petition, petitioner stated the following:              
               I have submitted an amended tax return (1040X) to the                  
               IRS addressing errors in my previous tax return                        
               (1040EZ).  I have also submitted an affidavit                          
               explaining how two “1099-MISC” forms (identified in the                
               “Notice CP2000”) are incorrect.  One was from “National                
               Quality Assurance USA Inc” and the other from “Labtest                 
               International Inc.”  Both “1099-MISC” forms erroneously                
               allege a payment to the party identified as he [sic]                   
               “RECIPIENT” of “gains, profit or income” made in the                   
               course of a “trade or business”.  I rebutted both of                   
               these documents in attachments to my amended 2003 tax                  
               return, dated September 9, 2005.  My amended tax return                
               did not indicate any greater tax liability than my                     
               original tax return.                                                   
          In the referenced affidavit, which was dated November 26, 2005,             
          petitioner stated that the Forms 1099-MISC from National Quality            
          Assurance USA Inc. and Labtest International Inc. “erroneously              

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