- -16 On October 3, 1991, respondent mailed a notice of deficiency to petitioners for the taxable years 1987, 1988, and 1989. Respondent determined, regarding the issues still remaining for decision for the year 1987, that petitioners' income should be increased by the disallowance of the claimed bad debt deduction of $70,000. Respondent determined that petitioner realized forgiveness of indebtedness income in 1987 upon the payment of the mortgage on the Third Street property in the amount of $69,815, and since petitioner had fully depreciated the property, he had unreported ordinary income of $43,318.80; and that the remaining $26,494 was capital gain income which petitioner failed to report in 1987. Respondent determined that petitioner's self-employment taxes for the years 1987, 1988, and 1989 were in the amounts of $5,387, $6,205, and $3,234, respectively, based on the amounts of fees the law partnership paid to him in those years under the purchase agreement.1 Respondent determined that petitioners were liable for additions to tax for negligence and substantial understatement of tax as set forth above for each of the years 1987 and 1988. 1 On brief respondent conceded that $2,235.80, $2,409.30, and $2,643.33 of the amounts she determined to be self-employment income represented payments for health insurance of petitioner and should not have been included in self-employment income.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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