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Respondent determined deficiencies in petitioners' 1988,
1989, and 1990 Federal income taxes in the amounts of $160,
$3,624, and $3,343, respectively. After concessions,2 the issue
for decision is whether rental income derived from certain
agricultural leases constitutes net earnings from self-
employment.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference. During the years in
issue, petitioners were husband and wife and filed joint Federal
income tax returns. At the time the petition was filed,
petitioners resided in Gould, Arkansas. References to petitioner
are to Lee Mizell.
Petitioner listed his occupation as "farmer" on his 1988,
1989, and 1990 Federal income tax returns. He has been engaged
in the production of agricultural commodities as a farmer most of
his adult life.
Over a period of years, petitioner purchased agricultural
land in Lincoln County, Arkansas. Specifically, petitioner
purchased 55 acres in 1978, 50 acres in 1979, 500 acres in 1986,
and 35 acres in 1988. Additionally, petitioner leased
2Petitioners conceded the correctness of adjustments for
auto depreciation in the amounts of $10,310, $496, and $298 for
the years 1988, 1989, and 1990, respectively.
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