Doyle A. King - Page 8

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          third party documents, as follows:                                          

          Source                                1990           1991                   
          Diversified 10, Inc. -                                                      
          Doyle's wages                        $2,400         $1,000                  
          Union Safe Deposit Bank                                                     
            interest                              260             20                  
          Stockton Savings Bank                                                       
            interest                              91              22                  
          U.S. Treasury                                          697                  
          King & Anderson Partnership           7,051                                 
          Delta valley Realty -                                                       
            Yvonne's non-employee                                                     
          compensation                        111,855                                 
          Phoenix International Marketing                                             
            Corporation                         1,998                                 
          Respondent concedes that neither Doyle or Yvonne received                   
          $8,000 in rental income for 1991, and that petitioners are                  
          entitled to a $6 deduction in 1991 for early interest withdrawal            
          penalty.                                                                    
               Doyle had a net loss of $12,610 from his Matol business in             
          1990. Doyle had discontinued his involvement with the Matol                 
          business by 1991, so is entitled to no loss deduction for that              
          year.                                                                       
               Doyle is liable for 1990 self-employment tax based upon his            
          net self-employment income from his Delta Valley Realty                     
          business,    reduced by a net loss of $12,610 from his Matol                
          business.                                                                   
               Doyle is liable for 1991 self-employment tax based upon his            
          net self-employment income from his Delta Valley Realty                     
          business.                                                                   






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