No Bona Fide Loan Resulted In Income From Services.

The petitioner worked as an independent contractor for a medical services company, was paid, but did not receive a Form 1099.  She claimed that the payment was a loan from the company, but the IRS determined otherwise.  The court agreed with the IRS.  The facts did not support characterizing the payment as a loan, and the owner of the company testified that the petitioner was paid for her services.  Fisher v. Comr., T.C. Memo. 2014-219.