Delgado v. Commissioner, T.C. Memo. 2021-84 | July 7, 2021 | Greaves, J. | Dkt. No. 191-20
Two companies paid the Petitioner for services performed as an independent contractor. The companies submitted Forms 1099-MISC, Miscellaneous Income, to the IRS reporting the payments. For the tax period, the Petitioner timely filed two Forms 1040EZ, Income Return, reporting zero income. Based on the two Forms 1099-MISC it received, the IRS issued a Notice of Deficiency, which provided an increase in tax liability as well as a section 6662(a) penalty. Petitioner timely petitioned the court for redetermination based on the Petitioner’s interpretation of section 7701(a)(26).
- Whether the IRS’s determination of the Petitioner’s tax liability and accuracy-related penalties is correct?
- Whether the Petitioner engaged in a trade or business as defined by section 7701(a)(26)?