Doyle A. King - Page 16

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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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