- 16 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011