- 6 - are as follows: (1) Whether each petitioner omitted from gross income his or her respective community property law one-half interest in the spouse’s earnings. (2) Whether petitioners had unreported Schedule C gross receipts for the years in issue, and, if so, then in what amounts. (3)(a) Whether petitioners are liable for the civil fraud additions to tax under section 6663, or (b) in the alternative, if petitioners’ underpayments (if any) are not due to fraud, then whether petitioners are liable for the negligence additions to tax under section 6662(a). 2(...continued) shows gross receipts of $82,721--petitioners acknowledge 1995 plumbing business gross receipts of $88,502. On brief, respondent indicates that respondent’s concessions have the effect of reducing the original deficiency notice determination by more than one-third as to Michael and by more than half as to Sandra. Further concessions were made in the course of certain postbrief proceedings. Infra note 24. Computations will be required under Rule 155. Unless indicated otherwise, all Rule references are to the Tax Court Rules of Practice and Procedure. 3 The following adjustments are computational: (1) The deduction for exemptions, (2) the child care credit, and (3) the computation of both Michael’s self-employment tax liability and self-employment tax deduction; their resolution depends on our determination of the issues for decision.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011