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get the trust income, if there was income. The 1991 "Corrected
Form 1041" for the Delta Valley Realty Trust reflected "Other
Income" of $202,454, and net income of $73. The scanty
information that petitioners have chosen to reveal about the
two trusts is insufficient to overcome the presumption of
correctness of respondent's determination, as modified herein,
for 1991.
Section 1401 imposes a tax on self-employment income of
individuals. Respondent properly determined that petitioners
are liable for self-employment tax on their respective business
incomes in 1990 and 1991. Section 164(f) provides a deduction
to an individual of an amount equal to one-half of the taxes
imposed by section 1401 for the taxable year. The amounts of
selfemployment taxes due and allowable.deductions under section
164(f) will be computed under Rule 155.
Petitioners are entitled to one deduction each for
personal exemptions under section 151, subject, however, to a
possible “phaseout" under section 151(d)(3). The allowable
amounts will also be established in the Rule 155 computations.
The Rule 155 computations will also give effect to
respondent's concession that petitioners are entitled to a filing
status of "married, filing joint return."
Section 6651 imposes an addition to tax of 5 percent for each
month, or portion thereof, that a return is delinquent, up to a
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