U.S. Tax Court Sustains Deficiency Determination for Unreported Form 1099-NEC Income

The U.S. Tax Court held that a taxpayer was liable for a federal income tax deficiency after failing to report $15,206 in nonemployee compensation reflected on Form 1099-NEC, despite claiming he received the form after filing his 2022 return. The taxpayer reported only $8,964 in total income and petitioned the court following the IRS’s determination of a $3,842 deficiency but failed to respond to the Commissioner’s motion for summary judgment. The court found that the IRS established an evidentiary foundation linking the taxpayer to the income-producing activity through undisputed third-party information returns, thereby shifting the burden to the taxpayer to ...