Doyle A. King - Page 9

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               Yvonne is liable for 1990 self-employment tax based upon               
          her   net self-employment income from her Yvonne King Real                  
          Estate Sales     & Service business. She is also liable for 1991            
          self-employment tax based upon her net self-employment income               
          from that business.                                                         
               Doyle is entitled to self-employment tax deductions for                
          1990   and 1991 under section 164(f) in amounts equal to one-               
          half of his self-employment income from Delta Valley Realty in              
          those years. Yvonne is entitled to self-employment tax                      
          deductions for 1990 and 1991 under section 164(f) in amounts                
          equal to one-half of her self-employment tax for those years.               
               Petitioners are entitled to itemized deductions in 1990 of             
          $9,739, which amount is mortgage interest of $12,777 less $3,038            
          of mortgage interest allowed on Doyle's 1990 Schedule C for                 
          Delta Valley Realty.                                                        
               Petitioners are entitled to itemized deductions in 1991 of             
          12,049, which amount is mortgage interest of $15,215 less $3,166            
          of mortgage interest allowed on Doyle's 1991 Schedule C for                 
          Delta       Valley Realty, and the $6 interest penalty referred             
          to above.                                                                   
               Petitioners made payments towards their 1990 tax liability             
          of $6,842, which consists of an estimated tax payment on April              
          15, 1990, of $6,659, plus a withholding tax credit of $183,                 
          based upon Doyle's wages from Diversified 10, Inc. Petitioners              






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