David Roy Callihan v. Commissioner of IRS

David Roy Callihan, proceeding pro se, appeals the Tax Court’s decision to sustain the Internal Revenue Service’s (“IRS”) determination of his income tax deficiency. Callihan concedes that in tax year 2007, he resided in Florida and that he worked for the School District of DeSoto County in exchange for $37,640, as well as the Sarasota Family YMCA, Inc. in exchange for $616. He insists, however, that none of his work constituted “employment” within the meaning of section 3121(b) of the Internal Revenue Code (IRC), 26 U.S.C. § 3121(b), and thus, the money he received in compensation for the…