Fernando and Maria Leonzo - Page 8

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               Respondent's disallowance of home mortgage interest for 1989           
          will be sustained.                                                          
          Self-Employment Tax                                                         
               Section 1401 provides for a tax on the self-employment                 
          income of every individual.  "Self-employment" income means the             
          net earnings from self-employment derived by an individual.  Sec.           
          1402(b).  Net earnings from self-employment income is the gross             
          income derived by an individual from any trade or business                  
          carried on by such individual, less the deductions allowed by               
          this subtitle that are attributable to such trade or business.              
          Sec. 1402(a).                                                               
               Petitioner had income from L&L in excess of the amount he              
          reported on his 1988 Schedule C and Schedule SE.  Accordingly,              
          petitioner is liable for additional self-employment tax.                    
          Respondent's determination will be sustained on this issue.                 
          Additions to Tax and Penalty                                                
               Sections 6653(a)(1) and 6662                                           
               Respondent determined that petitioners are liable for the              
          section 6653(a)(1) addition to tax for 1988.  Section 6653(a)(1)            
          imposes an addition to tax equal to 5 percent of the underpayment           
          if any part of the underpayment is due to negligence or an                  
          intentional disregard of rules or regulations.                              
               Respondent determined that petitioners are liable for the              
          section 6662(a) penalty for 1989.  Section 6662(a) imposes a                
          penalty in an amount equal to 20 percent of the underpayment of             




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