- 6 -
be computed on the basis of married, filing jointly, respondent's
protective position will be modified under Rule 155.
The notice of deficiency issued to Doyle was based upon the
adjustments in the following chart:
Item and Source 1990 1991
Wages - information from
third party IRP $2,400 $1,000
Interest - IRP 130 370
Doyle King's two 1989
Schedules C (Delta Valley Realty
and Matol) -
1990 and 1991 - CPI 9,075 9,456
One-half of Yvonne's 1989
Schedule C - Yvonne King
Real Estate
(1990 IRP income; CPI expenses)45,832
(1991 CPI based upon the
1990 figures) 47,757
Rental income - source unknown -0- 8,000
Exemption deduction (2,050) (2,150)
Self-employment tax deduction (641) (668)
Mortgage interest deduction -
1990 and 1991 - IRP (7,368) (7,536)
Schedule A phase-out amount -0- 477
Total adjustments 47,378 56,706
Income tax 11,565 14,137
Prepayment credit 3,330 -0-
Income tax balance
Self-employment tax 1,282 1,336
Total tax liability 9,517 15,473
(The Revenue Agent who prepared the original deficiency
notices totaled Doyle's 1989 gross income from the two Schedules
C and applied the CPI to that figure, and totaled Doyle's 1989
expenses from the two Schedules C and applied the CPI to that
figure to arrive at one combined 1990 Schedule C net income for
Doyle.)
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