George J. Smith & Sheila Ann Smith v. Commissioner

T.C. Memo. 2019-111

UNITED STATES TAX COURT GEORGE J. SMITH AND SHEILA ANN SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6105-16. Filed September 3, 2019. Ps omitted from their income tax returns amounts they received as interest and for work performed. Ps claim that, because R assessed I.R.C. sec. 6702 frivolous return penalties, he must make I.R.C. sec. 6020(b)(1) substitute returns for Ps before he can claim the returns they filed are incorrect. Ps also argue that they were not employees within the meaning of I.R.C. ch. 21 (Federal Insurance Contributions…