Hatch v. Comr., T.C. Memo. 2012-50

(petitioner worked part-time as clerical worker at drug addiction center on at-need basis in addition to janitorial job at a school; no written contract with part-time employer, but employer considered petitioner an independent contractor and did not withhold income tax; petitioner did not include amounts received from part-time job in income ($4,451) on basis that she should not have been issued Form 1099-Misc. or that payments were a gift; but, petitioner conceded that amounts received were for petitioner's services and, as such, are gross income from compensation; amounts are not gifts).