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At trial, petitioners conceded that: (1) The unreported
interest income of $45 is includable in their gross income for
the 1997 tax year; (2) the unreported capital gain income of $953
is includable in income for the 1998 tax year; and (3) the
unreported dividend income of $43 is includable in income for the
1998 tax year.
After the above concessions, the remaining issues for
decision are: (1) Whether petitioners are liable for self-
employment tax for the 1997 tax year; and (2) whether petitioners
are liable for an addition to tax pursuant to section 6651(a)(1)
for the 1997 tax year. Adjustments for the (1) self-employment
tax and the deduction therefor, (2) reduction to medical and
dental expenses pursuant to section 213(a), (3) reduction to
miscellaneous itemized deductions pursuant to section 67(a), and
(4) alternative minimum tax, if applicable, are computational and
will be resolved by the Court’s holding in this case.
During the years at issue, petitioner worked as an actor and
model. He has appeared in movies, stage presentations,
television shows, commercials, and print work. Petitioner goes
by the professional name of “Frank Isles”. Related to his acting
and modeling during 1997, petitioner received (1) combined wages
of $10,915 reported on 7 separate Forms W-2, Wage and Tax
Statement, and (2) self-employment income of $2,250 reported on
Form 1099-MISC, Miscellaneous Income. In addition, petitioner
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