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SMITHWICK v. COMMISSIONER

Docket No. 1458-92.

66 T.C.M. 1545 (1993)

T.C. Memo. 1993-582

A. Wayne and Roseanne M. Smithwick v. Commissioner.

United States Tax Court.

Filed December 9, 1993.

Attorney(s) appearing for the Case

V. Jean Owens, 1715 N. Westshore Blvd., Tampa, Fla., for the petitioners. T. Scot Simpson, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1988 in the amount of $11,346.04. All Rule references are to the Tax Court Rules of Practice and Procedure. The sole issue for decision is whether petitioners performed services as employees or as independent contractors during the year in issue.

Findings of Fact

We incorporate by reference the...

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