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to its customers. Wise conducted business through its employees,
one of whom was petitioner, and independent contractors. Wise
maintained a “business checking” account at Trust.
During 2002, NPC paid commissions totaling $75,929 to
petitioner and issued a Form 1099-MISC, Miscellaneous Income, to
petitioner evidencing those payments. As an NPC sales
representative, petitioner had two “rep codes”, one that tracked
the payment of “regular” commissions and the other that tracked
“override” commissions. The difference, if any, between the two
types of commission payments has not been made entirely clear.
Of the total commissions paid to petitioner by NPC during 2002,
regular commissions totaling $45,862 were directly deposited into
petitioner’s individual checking account at Trust, and override
commissions totaling $30,067 were directly deposited in the
joint checking account that petitioner maintained at Trust with
the other shareholders of Wise. Except for five direct deposits
that total $1,714, the funds directly deposited as override
commissions into the joint checking account were, within days of
each direct deposit, electronically transferred to Wise’s
business checking account at Trust.
The services that petitioner performed for Wise as one of
its employees are not entirely clear, but the services appear to
overlap to some extent with the services he performed for NPC.
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Last modified: March 27, 2008