Employee or independent contractor
On a recent court decision the tax court ruled that deputy that provide off duty services to other entities was independent contractor and not employee.
The entity that hired the deputy reported the earnings of the deputy on Form 1099 – Misc. The taxpayer reported the income from the job on his tax return but did not pay self-employment tax.
The taxpayer argued that he was an employee and was not subject to self-employment tax.
The IRS disagreed and the case ended up at Tax court.
The court looked at three aspects of the service:
- Service was performed and benefited directly third party entity and not the police department.
- The police department had no ability to hire or fire the deputy and the hire decision was made purely by the entity.
3. The source and method of payment to the deputy for this off duty work was purely up to the hiring entity.
4. The amount paid to the deputy was not reported on w-2
Based on these facts the court held that the deputy was independent contractor with respect to the off duty position and therefore the deputy is subject to self-employment tax on income earned from these job.
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