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.