MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined a deficiency of $8,464 in petitioners' Federal income tax for the taxable year 1991 and an addition of $1,693 under section 6662(a).
The sole issue for decision is whether petitioner Mario Mosteirin (petitioner) performed services as an employee or as an independent contractor during the year in issue, which in turn determines whether petitioner...
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